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Jeremy Jastrzab
23 Feb, 2010

How to make a submission: R18 Public Discussion

PALGN Feature | All the information you need, to make a submission. UPDATE: Less than a week to go!
With less than a week to go until the Public Consultation on Video Game Classifications closes on 28 February 2010, Gamespot reports that just over 6000 submissions have been received. Of the 1084 that have been processed so far, only 11 oppose the introduction of an R18 rating. However, we would have expected that the number of submissions would have been much larger by now.

Following several months of unexplained delays, the long promised R18 Public Discussion paper was released on 14 December 2009. We would have expected that gamers frustrated by the inconsistencies and lack of progression within Australia’s video game classification system would have been dying for a chance to have their voices heard. Made you submission yet? No? Then why not! It always seems like 28 February is far away but it is getting closer each day. And if it closes without you having made a submission, you’ll only have yourself to blame.

However, at PALGN, we accept that not everyone is Shakespeare. Not everyone has the ability, the time or the practice to sit down and right a succinct paragraph detailing a well argued summary of their beliefs. Well, neither do we, but we’re here to give you a helping hand. The aim of this article is to be a one-stop-shop for some basic information, as well as pointers and tips for making your submission.

Making a submission is just the beginning

Whether you have made your submission or not, you’d be naïve to believe that this is the end of the process. The public consultation is just the beginning of what could be a fairly long process because in many cases, it takes time for legislation to change. It can take even more time for government representatives to change their views on any given issue.

By making a submission now, you are taking your first steps in the journey towards the potential introduction of an R18 rating for video games in Australia. It’s only the beginning, not the end.

What’s the deal?

Since the classification system is applied nationally, all the States need to agree on any changes made to it. Upon the release of the first graphically violent games in the early 1990s, such as Mortal Kombat and Night Trap, ‘computer games’ were brought under the same classification system as publications and films – to be applied with the Commonwealth Classification (Publications, Films and Computer Games) Act 1995, the National Classification Code and the classification guidelines. However, upon establishment, an R18 rating was not introduced.

Without an R18 rating, any game that is deemed unsuitable for a mature rating of MA15+, is banned from sale in Australia. This goes against just about every classification system in the rest of the developed world. And as many of you have seen, leads to a system rife with ambiguity. Especially as games become more artistically complicated and more are aimed at mature audiences. According to the Games Classification website, the States have discussed the issue of the R18 rating several times, but until now, have yet to have a public consultation.

It’s not always the case that you get a chance to have a democratic voice in something that is of interest to you. So, if you want to have your say on the R18 issue, now is your chance. That’s unless you want a bunch of stuffy old politicians to make a choice for you.

Consultations, reforms and reviews

Clicking on the link above will take you to a world that until now has been unseen to many of you. Hopefully it’s clear though, that there are a number of pertinent social issues being examined at any given time. Furthermore, hopefully it will show you that you can have a say on things that are important to you when the time comes for it. And believe it or not, sometimes the suits will listen!

Frustratingly, it has taken over a year for the Attorney-General’s R18 public consultation to be released. However, now that it’s out, you don’t want this opportunity to have your say slip through your hands. The thing to remember though is that this isn’t going to guarantee that the rating will get through. What it will do, is help show the Attorney Generals that there is a genuine public interest in the issue.

What do you need?

If you’re reading this, chances are that you already have everything you need. All you need is a keyboard, Internet access and a few spare minutes. Also, you really should be at least 18 years old.

Where to go?

You probably don’t have to leave your computer to get all this done.

So, if you want to have your say on the R18 rating, the first place for you to go would be the Games Classification website, which gives you a basic run down of what’s happening. The who, what, when, where and how.

From here, you’ll have access to a summary of the main arguments, both for and against, the R18 rating. It’s definitely worth a read. Also, you’ll have the main article of concern, the ‘submission template’.

The summary of arguments can be viewed both as a PDF file, or a word document.

The PDF document can be accessed: here

The MS word document can be accessed through a link: here

The PDF document for the submission template can be accessed: here.

The MS word submission template can be accessed through a link: here

There are a lot of articles of interest at iGEA’s site, viewed here. In particular, you could check out is this open letter from iGEAs CEO, Ron Curry, which can be viewed: here.

And there is a whole heap of other articles and clusters of information out there as well. One article to check out is the Byron Review by child behaviour expert, Dr Tanya Byron, from the UK. The executive summary can be viewed: here, and you can see the entire site: here. The suits have got a lot of their information from here, so you’ll be able to see where some of them are coming from with some of their arguments. Oh, and we point to the executive summary, because the full report is a tad long…


To arms, fellow gamers and non-gamers! Show them that the pen (or keyboard) is mightier than the sword... Or petty annonymous Internet slang insults.

To arms, fellow gamers and non-gamers! Show them that the pen (or keyboard) is mightier than the sword... Or petty annonymous Internet slang insults.
Close

How does it work?

Once you’re happy that you’ve read through the arguments and you’ve made up your mind on the issue, you’re set to go. It’s simply a matter of filling in the prompts. Remember to make sure that you fill in all of the necessary fields, because if you don’t, your submission may be disregarded. And keep to the 250 recommended limit, because if it’s too long, it may be glossed over.

Probably the best way go about this, is to fill everything in word, make sure that the spelling and grammar checks are done and get someone with a good grasp of the English language to re-read your comments if you have any to make. Bureaucrats can be a little particular, so it’s important to get your comments to read as well as possible. A good tip would be to write it up tonight, and then proof read it tomorrow. That way, you’re more likely to pick up any mistakes. Also, you can use the ‘highlight’ feature to choose whether you agree or disagree with the given statements.

Once this is all done, you have three methods of delivery:

Email: classificationreview@ag.gov.au
Fax: 02 6141 3488
Mail:
Classification Review
Attorney-General’s Department
3 -5 National Circuit
BARTON ACT 2600

If you get a chance, we’d recommend that you send a copy through mail. We’re not sure who has access to fax machines these days, but as we mentioned, bureaucrats can be a bit particular, so sticking to ‘what they know’ can be a good thing. Still, if you were to email and mail your submissions, you’re just being diligent in making sure that they’re getting to their desired destination, right?

Good arguments to use

Here are some of the things that you can say that will help reinforce your argument (mind you, if everyone copies them word for word, it will look a little fishy):
  • The Classification Code sets out the following principle that the Classification Board must give effect to, as far as possible, in making classification decisions: “adults should be able to read, hear and see what they want”.

    The current gaming classification system doesn’t allow this without the R18 rating. As adults, we should be able to make our own entertainment choices without being dictated to by the government.

  • And according to the same principles, the R18 rating would still not allow classification for games that have “depictions that condone or incite violence, particularly sexual violence; and the portrayal of persons in a demeaning manner”.

  • Currently, there are a number of inconsistencies that are rampant in the classification decisions. As consumers, we are unable to discern what is acceptable and what is not, as one game will allow some things while another will not allow similar content. This affects our ability to make an informed decision. For example, Fallout 3 was banned due to detrimental use of known drugs, while Grand Theft Auto: Chinatown Wars allowed the buying and selling of known drugs and Velvet Assassin allowed players to explicitly benefit from one of the drugs that made Fallout 3 unacceptable. Having an R18 rating will allow for these ambiguities and inconsistencies to be cleared up, while providing everyone with more accurate information.

  • There is no conclusive scientific proof that video games have any more a negative behavioural impact on those who play as opposed to those who don’t or are more likely to have a negative behavioural effect due to their interactivity. As stated in the open letter from iGEA CEO, Ron Curry, the often citied study by Professor Craig Anderson linking games and violent behaviour is not widely accepted by his colleagues in the field of Social Psychology and Aggression, as they could not see enough evidence to link his behaviour model with the experimental evidence and that the study lacks “external validity”. Conversely, there are a number of studies that link playing games to improved reflexes, cognitive thinking and problem solving skills.

  • Enforcing R18 rated games for parents is easier then it ever has been before, as all modern consoles have security arrangements and ‘locks’ that can be set up by parents. This makes any games that are classified too high unplayable without parental permission.

  • Minors are just as likely to be exposed to inappropriate materials through television, film, literature and the Internet. This is not exclusive to games.

  • Indigenous communities and non-English speaking people are likely to have much larger concerns than whether a game is classified MA15+ or R18. Also, it would be much more difficult for them to directly access the illicit content in a game, especially if there is a language barrier.

  • The R18 classification category sends a clear, unambiguous message to parents that the game and its material are unsuitable for minors. Furthermore, this will help o the wider community and consumer base to understand that video games are no longer an entertainment medium solely dedicated to children, which is reinforced by the fact that the average age of gamers in Australia is 30 years old (iGEA) and especially as games become more complicated and artistically demanding.

  • Introducing an R18 rating will bring all the classification systems in Australia into line. This will help avoid confusion amongst consumers.

  • Introducing an R18 rating will likely minimise the number of people importing banned games. While this only applies to a small amount of games currently available, as the industry gets more mature and complicated, this could have a significant effect on Australian retailers in the future if consumers were to solely resort to importing form overseas rather than buying at home.

  • Australia is the only developed country in the world not to have an adult classification for video games. Furthermore, several media outlet polls and a Bond University study show that over 90% of respondents, including both ‘gamers’ and ‘non-gamers’, support the introduction of an R18 rating, as reported by iGEA.
Of course, these aren’t the only arguments that you can use. What you write, in the end, is up to you!

What not to do?

There are a couple of things that will not help this cause:
  • Do not provide false personal information, as it will discredit your submission. If you don't want your details to be explicitly used, choose 'yes' under 'confidentiality requested'.

  • Even though we can’t all be literary geniuses, make sure that you read through your comments several times before submitting them. It may sound silly, but you wouldn’t believe how much we miss in everyday life simply because none of us reads things thoroughly enough.

  • Don’t get angry and emotional. Avoid the use of caps (IT LOOKS LIKE YOU’RE SHOUTING) and emotive language that refers to things such as your rights, your personal preferences and anyone else’s mother. And above all, keep the language clean. Abusive and coarse language never got anyone anywhere.

  • Never use ‘Internet speak’. Even if the bureaucrats do managed to decipher “OMG, wr not n00bz”, they’re much less likely to take your argument seriously. Avoid abbreviations, whether they be connective like ‘btw’ or abusive like ‘gtfo!’.

  • Don’t write too much. It’s likely that they’ll have a lot of submissions to process. So keep to the point and be concise, otherwise it’s not likely to be read.

  • And above all, do not procrastinate. If you have not made your submission yet, do it as soon as possible!

Confidentiality

If you would like to be kept anonymous, this is directly off the Games Classification site:
Quote:
Unless confidentiality is requested, submissions are public documents and may be accessed by any member of the public, published on the Commonwealth Attorney General’s Department’s website and quoted in further review papers. If you do not want your submission to be published, or you would like to request anonymity, you must clearly request this in your submission.

The rest is up to you!

That covers just about everything. All that’s left for you to do is make your submission. I know that I’ve made mine. Make sure that you don’t let this rare opportunity for you to have your say slip through your finger tips. And while you're at it, make sure to tell your friends as well and get them to make a submission as well. If you have anything else that you would like to add or have already made your submission, please post in our forums. Just remember, that this is the first step on the journey and we have a long way to go.

Related Content

R18 discussion paper released
14 Dec, 2009 Government now taking public submissions.
An R rating would protect children
20 Mar, 2009 Michael Atkinson is right to want to protect children, he's just going about it the wrong way.
Part Two of our Steve Fawkner Interview
15 Sep, 2008 We talk about the local games industry, R18+ ratings and the future of Puzzle Quest.
40 Comments
3 years ago
Nice article Jeremy. I'll endeavour to put something together this week.
3 years ago
Well written. icon_smile.gif

Jeremy, do you think under 18s should make a submission? Does doing so hurt or help our cause?
3 years ago
Very well-written Jeremy and I hopet that people are able to heed your wise words on the issue, particularly what people should and shouldn't write in their submissions.

I'm really surprised with the miniscule number of people that have spoken against an R18 rating, even though I had a feeling that there would be more for it I thought the naysayers would be a lot more vocal than they are at present in voicing their opposition. Truly crushing numbers and if this gets a bit more momentum behind it and those proportions hold out it's going to be pretty hard for various talking heads to present any kind of argument that the community doesn't want a new rating system, especially in the wake of Atkinson's embarrassingly woeful appearance on Good Game.
3 years ago
JackSlack wrote
Jeremy, do you think under 18s should make a submission? Does doing so hurt or help our cause?
Yes and no.

I believe that there are a number of under 18s that could put together a better informed and argued statement than a lot of those who are over 18. Also, it shows that they are potentially mature enough to be aware of issues that may affect them. However, it is a valid point that under 18s that do make a submission could have their intentions misconceived.

So if someone under 18 does make a submission, it would have to be pretty well written. At the end though, it doesn't say anywhere that they can't make one.

Also, I just added a little bit about providing personal details that are true. Do it!

EDIT: Oh yeah, and spreading some love won't hurt either icon_wink.gif
3 years ago
I'll keep on shamelessly plugging my own version of this article, also. icon_wink.gif
3 years ago
On the under 18 aspect, I see no reason why it shouldn't, but at the same time a large enough group will simply provoke the same type of negative replies we've been getting anyway. It would entirely be selective however if we only "allowed" those of legal voting age to voice an opinion on the matter though.

As for mine, I took particular interest in the concept of need by an extension of the last question in the submission with incorporation. Hedging more on the aspect of choice and the inconsistency of the base line on it (proponent argument against) the encroaching elements already in existence (current classification system) and there inherent lack of it on an infringing viewpoint (gamers as rapists / parents absolved of all guilt given their child has access to the infringing material / "passing the buck" infringement on adults)

As to me it was all well and good to give questions which one can agree or disagree with, but the terminology used in some cases was open to interpretation and "need" was such a terminology. because let us face it we don't need entertainment since it is a luxury, we want it, we don't even need the classification system (perfect world scenario) but yet we need it simply because the alternative and the current system is too restrictive on general freedoms of the adult, the individual and the child.

Child gains access to material they should not.
Adult who spawned child unwillingly or otherwise promotes the problems of todays to the child.
Adult pays the price in civil liberties for said scenario, child pays the price in upbringing.

Of course, I wasn't so.. verbose or anything. But considering it is to be used for arguments sake in any event, defining terminology to highlight viewpoint and reasoning behind responses was deemed probably more important to me, since meaning generally gets lost in translation in most every case.
3 years ago
I've made my submission icon_smile.gif
3 years ago
This is a fine article here, and I encourage all the members to really read through this and send it around to anyone who can contribute to the cause.

The article has some fantastic guidelines on what you can and should write in your submission. The Do's and Don'ts listed above will really help you write up a solid argument, an argument that will surely make a difference.

I have already made my submission, and I basically covered the following two points:

Quote
1.Currently, there are a number of inconsistencies that are rampant in the classification decisions. As consumers, we are unable to discern what is acceptable and what is not, as one game will allow some things while another will not allow similar content. This affects our ability to make an informed decision. For example, Fallout 3 was banned due to detrimental use of known drugs, while Grand Theft Auto: Chinatown Wars allowed the buying and selling of known drugs and Velvet Assassin allowed players to explicitly benefit from one of the drugs that made Fallout 3 unacceptable. Having an R18 rating will allow for these ambiguities and inconsistencies to be cleared up, while providing everyone with more accurate information.

2. Introducing an R18 rating will bring all the classification systems in Australia into line. This will help avoid confusion amongst consumers.
Step up PALGN readers! Your voice matters!
3 years ago
friend-o wrote
I'm really surprised with the miniscule number of people that have spoken against an R18 rating, even though I had a feeling that there would be more for it I thought the naysayers would be a lot more vocal than they are at present in voicing their opposition.
well, there is this place, but it's just the same old rhetoric Atkinson keeps spouting. Bunch of uninformed and nonsensical scare-mongering designed to alarm old ladies. It's funny when you look at the examples of submissions they give... "no studies have proven that violent games can make people violent, but it's possible..."
3 years ago
Stupid articles saying it would let more violent games in. Most of the games banned areno worse than some games already out, and plus it would mainly let games be rated R instead of MA like they are now. They really need their facts straight.
3 years ago
Heck, we should all list our submissions here, in case anyone else wants some talking points to help them out. Just don't copy it directly, be inspired by it, don't copy it!

Quote
To the Attorney-General’s Department, thank you for opening this debate.

There should be no question that the current classification system for videogames is broken. Over the last two years alone, we have seen tremendous confusion and inconsistency in the rating of videogames. We also know that games rated for adults only in other countries routinely become rated MA15+ here, showing that the current system, far from protecting children, may well be putting inappropriate material into their hands.

This shouldn’t be happening. Contrary to the naysayer’s arguments, games are one of the forms of entertainment most controllable by parents; with modern consoles able to lock out games of inappropriate ratings at a parent’s request. The problem is that most parents don’t know this can be done.

We need to clarify, simplify and explain our system better. Introducing an R18+ rating, which only 33% of Australians realise we don’t have, is a valuable first step. We should follow the Byron Review’s recommendations – Rather than banning games, let us instead empower parents. Assist parents with a classification system they understand; that of film, including R18+ ratings and as similar guidelines for both as possible. Work with game manufacturers to simplify parental controls. Commission advertising explaining the system, and require game retailers to display it.

The need to protect minors and the right of adults to view what they wish need not be in conflict. We can have both, and this is why an R18+ rating is appropriate.

Again, thank you for this opportunity.
3 years ago
This article really drives home the extent to which interested gamers with an opinion should be rallying together in support of an R18+ classification for 'computer games'.

In fact, anyone with a modicum of respect for free-speech and individual liberty should take the time to write a brief submission and make themselves heard. I am presently preparing my own; as a mature adult with a genuine passion for the medium, I think it vitally important.

Terrific article, Jeremy. Let's aim to fix this sadly-broken state of affairs.
3 years ago
The message of the article is simple: now is the time for action.

For all of PALGN's readers who have debated this issue over the past few years, it's time to do it again in a concise and meaningful way. By all means keep debating it among yourselves, but also make sure you put in an 'official' submission.

It's also important to put this into context; this debate isn't simply about us silly gamers getting our violent toys. This debate has greater implications for a democratic and free society which shouldn't be forced to live under archaic laws not imposed on other free and democratic societies (many with low violent crime rates like Australia).

This is as much about demonstrating to those people in positions of power that Australia's values and integrity should be shaped by society itself as a whole; not by a favoured few with vested interests and extreme, uneducated opinions.

The catch-cry of the opponents to an R rating is "think of the children". But think of the children who will be forced to live in a country where during this critical period of censorship (also including the proposed Internet filter) we handed power over to politicians and so-called family groups to judge what the values of our society should be.

If we don't speak up now, what will they censor or filter or ban next in the name of preserving the fabric of society and saving the children?

But by the same token, if you agree with the lack of an R rating, then please let them know. That's your right as a free citizen and one which a free society should respect.
3 years ago
FWIW, here's my honest truth opinion over what will happen:

Nothing.

But...

It benefits us to submit anyway. In the end, big numbers of submissions in favor help us. Atkinson may stonewall, but other AGs may be moved to come out publicly in favor. In the end, it helps us. I don't think we have any realistic chance of getting an R18+ rating at this juncture... especially as I'm convinced the timing of the discussion paper's release was co-ordinated to maximise distraction from the net filters. But it's worth doing anyway.
3 years ago
There are other options though. The ACT's AG said there may be reason to change the laws if public opinion was strong so that the introduction of the R rating (or other popular changes) can't be stopped by one AG.

That option would take a long time, but the important thing is that we actually make the effort to show we care, otherwise why should they?
3 years ago
Jason Picker wrote
That option would take a long time, but the important thing is that we actually make the effort to show we care, otherwise why should they?
Exactly. Regardless of what happens here, this is a chance for us to advance the issue and make it a bigger one. We owe it to ourselves to make sure that happens.
3 years ago
What you guys say about the lack of immediate action is quite true and this is a process that could take some time. However, we've got to persist. Think of making the submission a beginning to the process, not the end solution icon_smile.gif
3 years ago
Mailed in my submission 2 weeks ago. I really hope there is a relatively quick decision on this. Also, some feedback from the gov't on this would be nice.
3 years ago
Nice read Jeremy!

I'm quite passionate about this subject, but I'll admit that I hadn't done anything to voice by opinion until today. I managed to get some work buddies to sit down with me at lunch and hash it all out. In the end we've mailed off 10 consise and mature submissions into the mix for consideration.

Let's all make the effort to put the controllers down for a second and pick up your pens so the government can hear it from out side. icon_biggrin.gif
3 years ago
Fantastic article Jeremy.

As individuals, we rarely have an opportunity such as this to be heard by those in power. If you’ve ever lamented missing out on a game for the lack of an R 18 + rating, now is the time to act. You may think a single submission may not have much force, but time spent preparing a submission will add invaluably to the collective message that our system has been out of sync with the world for far too long.

If you’re tired of being ignored, put pen to paper. We should have the right to make an informed choice as to the games we play. If you can write that on paper, you’re already half way there. Simply follow the guidelines above, and you will have succeeded.
3 years ago
Excellent article Jeremy. I'm a very passionate gamer, and it always hits me in the chest whenever I read someone opposing the R18+ rating.

I mean, come on, the military/navy/airforce and police force train people to use guns. While I know it isn't the same, it's laughable to think we have these politicians saying videogames do the same thing. In all honesty, it's like shooting a waster pistol on a hot summer's day - its all innocent fun and does nothing to alter one's mind. How many of you guys played with waterguns then went out in public shooting innocent bystanders thinking it was all a game? No one? Exactly.

Yeah, I probably could have come up with a better example, but my point is I'm a firm supporter of the R18+ rating for video games.
3 years ago
is R18+ as a category already happening?

Was on PSN and dante's Inferno actually had that on its page and I noticed the R18+ tag on it. Had to wonder, Is it already going ahead and well, the politicians already know its happening and well, are using it to milk votes?
3 years ago
I hope they can come to a quick decision next week.

Like a poll on news.com.au I saw, I expect that roughly 95% will be in favour of the R18 rating icon_biggrin.gif.

They've been awfully stubborn about this, so I hope they don't pull anything.
3 years ago
THEMAN wrote
is R18+ as a category already happening?

Was on PSN and dante's Inferno actually had that on its page and I noticed the R18+ tag on it. Had to wonder, Is it already going ahead and well, the politicians already know its happening and well, are using it to milk votes?
Probably not.I was thinking the same thing but when I looked at AvP on the store it said MA15+ and I'm sure if the above was the case then AvP would have also had the R18+ tag.
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