Preparing for a national framework.

October 9, 2024

Isabelle Mondou
Deputy Minister, Canadian Heritage
Government of Canada

Dear Deputy Minister Mondou:

I hope this reaches you in good health and fine spirits despite all your complicated files.

As you no doubt know, Bill S-269 is about to clear Third Reading in the Senate, and move to the House of Commons. We thought it would occur last night, and Senator Deacon is confident it will happen soon. As soon as that happens, the Campaign to Ban Ads for Gambling will resume a full court press on the Government and MPs from all parties to pass the bill. Before the bill was stalled in the Senate last spring, we had commitments for support from MPs in all five parties. It seems that the House of Commons is bitterly divided these days but I am still hopeful that we can get a strong bill approved with royal assent before the next federal election.

I trust that your own inter-departmental preparations for the implementation of the legislation and the creation of an appropriate regulatory framework when it passes continue to go well. I remain excited about the possibilities of the launch of a pan-Canadian educational campaign about the harms of sports betting and other forms of gambling in connection with the men's FIFA World Cup that you mentioned on our very first call. If we can help in any way, please let us know.

I am writing today on two matters:

First, to request that Canadian Heritage initiate or work with other ministries (such as Health) to undertake a comprehensive study of the incidence of sports betting and other forms of gambling among Canadians, to establish rates of gambling disorders among Canadians of different age groups, gender, regions of the country, etc. Up until recently, the only data we have been confidently able to use have been drawn from the Stats Can report of 2018, collected three years before legalization. Very recently, in June, the Mental Health Institute of Canada reported that 7% of Canadians (15% among Canadians between 18 and 34 years of age) present high risk of problem gambling, more than four times the 1.6% that Stats Can found in 2018. While the MHIC is a reliable organization, I would feel much happier if we had a second survey, with data from a larger sample, with full peer review, etc. Given the public policy importance of this issue, solid, comprehensive data are needed.

Second, to let you know that the Campaign to Ban Ads for Gambling continues to press all levels of government on the need to minimize and prevent gambling harms. As you can see from our September Bulletin (No. 13, September 12, 2024), we filed another complaint with the Ontario regulator, the Alcohol and Gaming Commission of Ontario, on the blind eye it takes to Ontario betting operators seeking and accepting bets in other jurisdictions, despite their illegality. Unfortunately, AGCO takes the old excuse that since the matter is before the courts, it cannot act. While we were unsuccessful in obtaining intervenor status before the Ontario Court of Appeal in Ontario's application to permit companies to seek bets outside Ontario, we will attend the hearing at the end of November and try to make our case to the media in attendance. We also seek to get the Toronto Board of Health to make a strong statement against ads for gambling, and to call for much greater public investment in harm reduction, education and research.

Many thanks again for listening.

Keep up the important work.

With all best wishes,

Bruce Kidd
Campaign to Ban Ads for Gambling