SUBMISSION 31
Memorandum submitted by the British Association
of Leisure Parks, Piers & Attractions Ltd
EXECUTIVE SUMMARY
1. RECOMMENDATION
32.
We propose that all operators of machines in
Categories A-D be licensed.
2. RECOMMENDATIONS
44-47.
We propose that Established Rights (Grandfather
Rights) should apply to premises.
3. RECOMMENDATION
51.
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).
4. RECOMMENDATION
55.
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.
5. RECOMMENDATION
58.
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.
6. RECOMMENDATION
60.
We propose that the planned research study should
include all vulnerable categories, not just children.
7. RECOMMENDATION
61.
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.
8. RECOMMENDATION
71-73
We propose that operators able to comply with
agreed criteria for restricted premises be permitted to operate
four Jackpot Machines.
INTRODUCTION
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.
EVIDENCE RATIONALE
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
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