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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
2 years ago
i know this may seem a stupid thing to say but...but isn't this all pointless until that Attorney-General Michael Atkinson retires or something?
2 years ago
jason picker wrote
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.
2 years ago
This is an extremely helpful article Jeremy, I'll definitely be using it over the weekend so I can get my submission ready to go, and I would encourage anyone who hasn't yet to do the same.

It's the best thing any of us can do at this point in time to help get an R18 rating for games in this country.
2 years ago
Thanks for the article. I had almost left my run too late. So I submitted mine on Tuesday.
2 years ago
This is an incredibly helpful article for anybody who has an opinion on this and wants their voice heard, but didn't previously know how to go about making a submission.

I don't need to go into how important having an R18+ rating is in this country; so just go ahead and make your submissions, folks!!
2 years ago
I am probably the only hardcore gamer that doesn't want an R18 rating I guess. Or rather, doesn't mind if I miss out on some games because of it.

A couple of points:

- The current system is too inconsistent. There is no way in hell that Modern Warfare 2 should have been ok'd. Even the God of War 3 demo pushed the boundaries beyond what I thought was possible for MA15+.

And some banned/refused games are not even that bad from what I've seen or experienced.

- Saying stuff along the lines of if the majority of the public are for 18+ then that strengthens the case is funny. If 99% of a country was for easy access to guns or porn, would majority rule? Of course not.

- I for one, bought MW2 and am going to buy Gof of War 3 day one and enjoy the violence but wouldn't whinge if they never got released here and will also still play them without excessive the violence.

- I am 32 and can safely say I have never been and never will be influenced by any violence or whatever from games... and I'm sure MOST gamers would be in the same boat. However, the fact of the matter is, kids are easily influenced and the parents of the modern generation are pathetic excuses for parents and not only don't know or care what their kids do, but sometimes are even responsible for providing them with content in DVD's and games that they have no reason to be seeing/playing.

Were I used to work, I told a kid he was too young to buy GTA... 5 mins later his Mum comes up to buy the game, I tell her exactly what's in the game, she hesitates for a second, the 11 or 12 year old kid swears and threatens the Mum and she buys it for him.

- Australia has been a MUCH safer place (or rather, has not progressed into a more dangerous place) since removing firearms and any little thing they can add to that (including, not allowing unnecessary content into the country through games) will only help.

Sure we have the right as adults to watch and play what we want but seriously, does an extra splash of blood or a graphic murder scene really add to a gaming experience?

Of course bloody not.
2 years ago
Peoples!

There are only a few days to go. If you haven't made your submissions, you should do it as soon as possible!
2 years ago
MX in Sydney had a story about this on their front page yesterday. They said Grow Up Australia had received about 6500 submissions (to be forwarded on I believe) but the more that are sent in the better. Submissions are due by February 28th, so get them in ASAP. There's no point waking up on March 1st and wishing you'd sent something, anything in!
2 years ago
Also get the message out to your friends any way you can!
2 years ago
Come on guys, the more the merrier. Our gamer pride depends on it!
2 years ago
EBGamesAus

Two words: WOW + THANKS! We had over 46,000 submissions for the R18 debate! Great work all! http://tinyurl.com/yght2yb

found that over twitter , guess that's where all the submissions are going
2 years ago
Good article Jeremy. I submitted mine a few weeks ago now.
mikezilla2 wrote
EBGamesAus

Two words: WOW + THANKS! We had over 46,000 submissions for the R18 debate! Great work all! http://tinyurl.com/yght2yb

found that over twitter , guess that's where all the submissions are going
If that is true then R18+ is that much closer icon_biggrin.gif .
2 years ago
They reported on Triple J news yesterday arvo that the government received over 50,000 submissions, which is the most for a public discussion in Australia ever.

Hopefully they were mostly in favour of the R18+ rating icon_smile.gif Its a good sign.
2 years ago
EB Games reported sending 46,000 submissions. 56 thousand (or so) submissions were received. Which just shows you how freaking huge EB is.

So, minimum? 82% were supportive. Probably closer to 95%+, but that's a pure guess.
2 years ago
Benc82 wrote
They reported on Triple J news yesterday arvo that the government received over 50,000 submissions, which is the most for a public discussion in Australia ever.

Hopefully they were mostly in favour of the R18+ rating icon_smile.gif Its a good sign.
Over 40,000 of those came from the EB system, so I'd hazard a guess they were almost all in favour.

edit: well it's obvious I didn't read Jack's post before jumping the gun.
2 years ago
At least you didn't resurrect a two year old thread today, Spanca. It's my idiot ball today, and I'm packing it up and going home. icon_smile.gif
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