Thursday, February 18, 2010

An R18 Discussion Paper Submission Letter

December last year the long awaited Discussion paper regarding an R18+ classification for games was finally released. With only a week remaining until the cut-off date for submissions, tallying has already begun. Although this is a call for feedback only – not a vote – results so far positive. I submitted one myself of course, but in addition to this I wrote a rather lengthy letter my local Attorney-General Cameron Dick, as well as Brendan O’Connor, Minister for Home Affairs.

The letter is a collection of thoughts and concerns regarding the R18 debate. I tried to avoid many of the points commonly bought up by pro-R18 supporters (though I still touch on several where relevant) simply because so many others have done a great job of bringing them up in their own submissions with reference to the compelling Interactive Australia research. Instead, my submission is more a personally letter based on my own opinions, experience, and reading.

The letter is as follows:

Dear [minister],

I write concerning the call for public consultation regarding the introduction of an R18+ classification for video games. I am delighted to see that the long promised Discussion paper on this issue was released last December, and have submitted a response myself. However, I feel that a more in-depth, personal letter is also necessary in order to fully express my thoughts on this issue.

I am a twenty-six year old game developer employed at Krome Studios, an Australian owned and operated video game company with studios in Brisbane, Melbourne, and Adelaide. I am a member of the International Game Developers Association (IGDA) Brisbane Chapter, and frequent many game developer and consumer related conferences and events throughout Australia. In my spare time I am not only an avid player of games, but also enjoy studying gamer culture and how games intersect, influence, and reflect culture at large. Therefore my interest in this issue is that of a professional, a consumer, and a hobbyist.

I would like to address a few key issues that continuously pop up in this debate, namely:

  • The impact of video games on players and the significance of interactivity
  • The range of adult games available
  • The ability for parents to restrict their children’s access to adult games
  • Games as art and entertainment, their place in popular culture, and why we need an R18+ rating.

The impact of video games on players and the significance of interactivity

A key issue of the debate has been that because games are interactive, they are therefore of greater concern than other media such as film, where the viewer plays a purely passive role. I feel that this concern arises from key misconceptions about how people engage in games (and media in general).

Firstly, it is important to recognise the difference between the media content of a game and the gameplay systems. People unfamiliar with games often confuse these elements: they see players engrossing themselves in the violence and gore but do not see the underlying gameplay systems that are actually concerned with things like reaction time, problem solving, and teamwork. To use film as an analogy: it is the difference between the underlying plot and the imagery as presented on screen. It is important to understand that when a player is playing a game they are not mindlessly absorbing the content, but actively engaged in a complex system of rules and goals, stimulating a variety of thought processes including problem solving and creative thinking. It is also incorrect to assume that a player is focused entirely on one or the other. Instead a player’s mind is constantly shifting between both aspects, at one moment engaged in the imagery and the next moment considering how many seconds are left in the round. Players interpret each element individually as well as find meaning in the experience as a whole. This is not meant to discount the impact of the media content, but to recognise that watching bloody death animations and achieving a high score from 20 “kills” are two very different things.

Secondly, critics of violent games often cite players ‘rehearsing violence’, or liken their effect to military training simulations – they say players are training themselves to be violent. This assumes a direct transference of ideas that removes all room for context, interpretation, and player expression. No media is ever experienced without context, and people simply do not learn this way. People interpret games (and indeed all forms of media) in their own individual way, retaining some information and ignoring other parts, and interpreting all of it based on their own unique past experiences. It is not simply a case of “monkey play, monkey do”.

I find it unsurprising that the Byron Report (referenced in the Discussion paper) found studies into the effects of video game violence to be so polarised. It is difficult to separate the effects of the media content from the gameplay interaction, and therefore difficult to compare them to other forms of media or interactive activities (like aggressive sports). And they rarely, if ever, consider how players assess the media and interaction with regards to their own life experience.

It is part of my job as a games developer to understand how my product affects people (indeed in order to create any media product you need to know how your medium engages people). As someone who has spent years developing games as well as investing time into personal study of video game theory and its relation to other media types, I believe I speak with some authority on the issue. Certainly more than the many lay-people who assume that because something is interactive it must necessarily have a greater impact. I maintain that interaction affords more powerful expression than passive media in some ways, while being weaker in others. I firmly believe that violent games are no more or less harmful than other types of violent media– rather their ideas are simply expressed in a different way.

The range of adult games available

One great fear of an R rating is that its introduction would result in a sudden flood of high level content. This is a ridiculous assumption that ignores the reality of the video game market: game content is dictated by the massive United States and European markets. In the US, many retailers (including Gamestop and Walmart which together make up a significant portion of game sales) refuse to carry games with an AO rating, and several platform holders (including Sony, Nintendo, and Apple) do not allow these games to be published on their platforms. Developers actively cut back content to fit into the M17 category (roughly equivalent to our R18, yet many of these games are released in Australia with an MA15 rating), as exceeding it is effectively a death sentence for the game. As a result the number of AO level titles released (whether from the US or other countries) is significantly small and are mostly distributed digitally via small online retailers – an R rating will not change this. While an R rating would open up the potential for more extreme titles to enter Australia, it is ridiculous to assume we would see a sudden influx of ultra-violent titles because Australia, one of the world’s smallest game markets, suddenly allows it.

The range of titles available under an R rating will be no more extreme than those currently available in unedited form overseas. If anything, an R rating will reduce the number of games squeezed into an MA15+ rating. Fallout 3, which was Refused Classification in 2008 was released with two edits: The animation showing the player injecting drugs was removed, and the drug ‘Morphine’ was renamed to ‘Med-X’. Yet this does not change the fact the game still deals in adult themes, and all the ultra-violence, coarse language and (now non-animated) drug use remains – but it can now be sold to children (incidentally, within days of the game’s release a user created modification was released online that renamed Med-X back to Morphine, effectively undoing half of the censorship). Additionally, more than 50% of titles classified MA15+ last year were classified as 18+ or equivalent overseas. This shoehorning of adult games into the MA rating stretches the MA spectrum beyond rational understanding. Fallout 3 at the high end of the spectrum is vastly different from Uncharted 2 at the low end, a game with a level of violence comparable to a James Bond movie.

Far from allowing hoards of vastly more extreme titles into the country, an R ratting allows for more accurate classification of existing levels of content, and clearly separates edited or shoehorned games like Fallout 3 and Grand Theft Auto from those acceptable for minors.

The ability for parents to restrict their children’s access to adult Games

Critics argue that it will be difficult to keep R rated games out of the hands of children. Personally, I find all arguments for this conclusion unsatisfactory. An R18 rating sends a clear message to parents that these games are not meant for children, and stores are already encouraged to refuse sale to minors – a process that is deemed acceptable enough at a video store or movie cinema and legally enforceable under an R rating. Yet games have even further restrictions in the form of parental locks which can be found on all major consoles, handhelds and the Windows operating system. Nothing short of guessing the password will allow a minor to play an adult game on a console with this setting enabled. (While it is noted in the discussion paper that older consoles do not include parental locks, these legacy systems are no longer being manufactured and no new games are being developed for them).

It is ridiculous to assume children will have access to adult games any more than they will other media, especially when games have more restrictions and parental aids in place than other media. Indeed, even non-media products such as cigarettes and alcohol which have very serious detrimental effects and cause numerous health and social problems are less easily restricted than video games. If parents and society can restrict children’s access to other adult media with existing safeguards then it follows the same can be done for games – to say nothing of the extra protection afforded by parental locks.

Existing restrictions, along with education and parental responsibility, offers more than adequate protection.

Games as art and entertainment, their place in culture, and why we need an R18+ Rating

As a developer and a hobbyist I not only develop games at work, but also in my spare time. I hope to create games that push the boundaries of the medium, to explore meaningful adult themes and tackle difficult social issues – and so do many others like me. But not only are such games illegal to sell in Australia, a lack of and R rating means that it is not legal to even develop them here. How can any Australian developer hope to develop meaningful games that explore complex adult topics when the law says we can only make games for children? Aside from being restrictive artistically, it’s downright insulting. As an adult I demand the right to develop and play games with adult themes. It is incongruous that a medium so rich and diverse in art and culture such as games is still considered frivolous children’s entertainment by the Australian Government.

Video games have become as much a part of art, culture and entertainment as any other form of media, and around the world people are exploring the full spectrum of what this means:

  • During 2008 and 2009 the Game On exhibition toured Australian museums and art galleries, exhibiting the history of games as art and entertainment
  • In 2007 PLAY! A Video Game Symphony preformed at the Sydney Opera House as part of their world tour
  • Many major awards ceremonies now include game related awards, including the Writers Guild of America and the British Academy of Film and Television Arts (BAFTA)
  • In November last year the game Modern Warfare 2 recorded day-one sales of over US $310 million, making it the biggest entertainment launch in history eclipsing even major Hollywood films. The previous record holder was another a video game, namely Grand Theft Auto IV (significantly, both games are made for adults and rated 18+ or equivalent in other countries, and MA15+ in Australia).
  • Large numbers of movie releases are now accompanied by a video game version
  • The success of Nintendo’s Wii has put games into the homes of traditional non-gamer consumers - including even senior citizens
  • And in March this year Australia’s first video game themed bar is opening in Brisbane’s Fortitude Valley – legally serving alcohol to 18+ gamers.
It is fair to say that games have become a powerful economic and cultural force that intersects all areas of our media consumption and increasingly our daily lives. Video games have become the primary entertainment medium for a vast number of Australians, whether they play on a 52” screen in their living room or a 2” screen on their phone. Indeed, games have become so ingrained in our culture that they are becoming as synonymous with our daily lives as television or mobile phones.

Already the distinction is blurring – Facebook games are as much social networking applications as they are entertainment. Consoles are no longer dedicated game machines and instead act as centralised media hubs, supporting games, video, music, web browsing, social networking feeds like Twitter and Facebook, and acting as gateways to online communities. People are meeting in online games, building friendships, even hosting weddings in Massively Multiplayer Games. Concerts, film premiers, and even political speeches are being simulcast in online worlds like Second Life, and game technology is increasingly being used in education and academic research.

This convergence of life and media is only going to increase, the percentage of the population playing games is only going to increase, and the average age of gamers is only going to increase (according to the latest studies it currently sits at 30).

Games represent the driving force behind 21st century entertainment culture. To neglect an adult rating is to deny this fact. A medium with such cultural and economic significance, enjoyed by people of all ages, should not be restricted by such outdated classification laws. Games are serious form of entertainment enjoyed by millions of adults Australia wide, and it’s time they were recognised as such.

At the next Standing Committee of Attorneys-General meeting I request that you acknowledge video gaming for the diverse and significant medium that it is, and show support for an R18+ rating.

Yours sincerely,
Ben Droste


  1. and what did they say to that?

  2. I received replies from both the Queensland AG and the Minister for Home Affairs, the latter was your stick-standard reply: "the classification code rates blar blar blar, currently there is no R18 rating for games etc. etc. The government has released a discussion paper yadda yadda yadda. Thank you for your letter, signed - some secretary"

    The Queensland AGs reply was much better, as it actually detailed the history of why the decision was made to not include an R18 rating originally, which implies he is open to the idea that circumstances have changed since then.

    Now the results of the discussion paper have been collated, we can only hope they take the results seriously and make a sensible decision.