Select Committee on Culture, Media and Sport Memoranda


Memorandum submitted by the British Association of Leisure Parks, Piers & Attractions Ltd



  We propose that all operators of machines in Categories A-D be licensed.


  We propose that Established Rights (Grandfather Rights) should apply to premises.


  We propose that 16 and 17 year olds should be permitted to work in catering or retail areas in amusement facilities other than those operated under Section 34.5 (E).


  We suggest that the matter of security for the location of ATM's should be considered, in addition to allowing players a break from use of gaming machines. The vulnerability of these machines to vandalism and theft is of great concern to operators.


  We propose that a second level of Category D be introduced to allow Cranes (Grab Machines) and Redemption Machines to continue to be operated on 30p stake, maximum £8 non-cash prize.


  We propose that the planned research study should include all vulnerable categories, not just children.


  We propose that stakes and prizes for Category D machines should not be fixed. The Gambling Commission should be given the power to review these issues.


  We propose that operators able to comply with agreed criteria for restricted premises be permitted to operate four Jackpot Machines.


  The Association, established in 1936, represents the interests of 113 theme parks, amusement parks, and piers, accounting for almost 100 per cent of that sector of the Attractions Industry. The majority of our Membership consists of family owned and operated facilities, many of which have been passed down over several generations. Additionally, larger organisations such as The Tussauds Group and Leisure Parcs are Members.

  BALPPA submitted a detailed response to the Gambling Review Report, detailing its concern on the effect some of the recommendations would have on the continuation of business for some of our Members.

  We are grateful that several of the recommendations likely to cause great concern to our Membership have either been rejected by the Government or varied to lessen the impact on their livelihoods.

  In submitting this evidence we wish to refer to several outstanding issues of concern which we believe could be modified without risk to the original objectives of the Review.

  For ease of reference we have used the Recommendation Numbers as published in the Gambling Review Report and A Safe Bet for Success.


  Recommendation 32

  We propose that all operators of machines in Categories A-D should be licensed to avoid the possibility of any relaxation in current practice attracting inexperienced and potentially unscrupulous operators.

  Recommendations 44-47

  The proposed powers for local authorities to license premises does not recognise the established rights of existing premises.

  We propose that such rights be recognised by permitting the transfer of permits, still allowing controls by the Local Authority to refuse licences if new operators were not considered suitable to hold a licence.

  Recommendation 51

  As currently worded the Recommendation would not allow 16 and 17 year olds to be employed in amusement premises. We draw the comparison with lottery sale outlets, which does permit this age group to be employed.

  We propose that a restriction on this age group should only apply to areas operating machines under Section 34.5(E) (Category C) permits or Adult Gaming Centres.

  Recommendation 55

  The Recommendation addresses the need for players to break from using machines in order to use an ATM. We support the principle but propose that the security of the machine and its contents should be an additional consideration when agreeing a location. Instances of vandalism and theft are likely to increase unless the security of the machine is added to the criteria in deciding location.

  Recommendation 58

  This Recommendation proposes that all machines in Category D be operated to a maximum 10p stake and £5 cash or non-cash prize. This was not a recommendation made by The Budd Report which recognised that cranes/grabbers and redemption machines were not gaming machines.

  Whilst we support Budd's conclusion on the description of the machine, to avoid attracting new operators with insufficient "good practice principles" we do not think it appropriate to remove the need for licensing operators.

  The crane/grabber and ticket redemption machine is one of the most traditional family amusement machines and should not be restricted by prize value. For many years they have provided fun and entertainment for families wishing to play and win a cuddly toy or similar.

  The standard and quality of the prize available is the vital factor for the viability of the machine. In many cases Licensed Product such as that promoted by the latest Disney film or TV Cartoon programme prove to be the most popular prize, particularly with families. Licensed Product is also the most expensive to purchase, in most cases a wholesale price over £5 is usual.

  The Recommendation as currently proposed will lead to a severe decline in the popularity of this machine due to either a significant reduction in the chances to win at 10p per game or a reduction in the quality of merchandise provided for prizes.

  We propose that a second level of Category D be introduced to allow the Crane/Grabber and Redemption Machine to retain the existing practice of 30p play, and only £8 maximum value non-cash prize.

  Recommendation 60

  We support the proposal for new research to identify whether or not use of gaming machines produces a propensity to develop a gaming habit. We propose that such research should include all likely vulnerable groups.

  Recommendation 61

  It is proposed that the stake and prize level for Category D machines be frozen to 10p and £5. We maintain that this does not recognise the impact of other factors such as VAT and minimum wage increases, or the introduction of the Euro.

  We propose that the decision on stakes and prizes for Category D machines be placed with the Gambling Commission who will be able to evaluate such decisions in light of all contributing issues.

  Recommendations 71-73

  We propose the recommendation to allow four jackpot machines with a maximum prize of £500 to be operated in LBO's, Adult gaming centres and bingo halls be extended to controlled amusement premises within premises that are restricted to over 18's.

  We propose that a clear criteria be agreed with the Gambling Commission that allows operators the option of installing jackpot machines providing they are able to comply with the criteria.

  This concludes the submission of evidence.

16 May 2002

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2002
Prepared 11 June 2002