Select Committee on Regulatory Reform Thirteenth Report

5 Assessment of the proposal against the Standing Order criteria


40. Our predecessor committee, the Deregulation Committee, examined no fewer than eight deregulation orders amending various aspects of the 1968 Act. In its report on the proposal for the last of these, the Deregulation (Bingo and Other Gaming) Order 2001, published in May 2001, it noted its concern that the regulatory reform procedure was being used to make piecemeal changes to the Act, adding complexity to the statute book.[19] That Committee noted the issue in March 2001 of the Home Office consultation document on this very proposal, which it believed was likely to "arouse some dissent".[20] It recommended that its successor committees should pay particular attention to the possibility that the cumulative effect of further amendments to the law by regulatory reform order might represent a "'substantial' or 'manifestly controversial'" change to the law which might be more suitable for primary legislation.[21]

41. In view of the concerns expressed by our predecessors, we have examined whether the proposal is indeed appropriate for the regulatory reform procedure. In our view, the present proposal does not purport to make a substantial or controversial change to the 1968 Act of a kind which might be better proceeded with by means of a bill. We believe that the proposal appears appropriate for delegated legislation.

Removal or reduction of burdens

42. The Department believes that the present legislation imposes "outdated requirements which add unnecessarily to costs and prevent the flexible use of modern technology" by gaming machine operators and suppliers.[22] It indicates that the proposal would remove three burdens imposed on gaming machine operators by the 1968 Act:

a) a requirement that jackpot and higher-value AWP machines shall be operated solely by coins[23]

b) a requirement that jackpot and higher-value AWP machines must be able to accept payment for a single game,[24] and

c) a restriction preventing jackpot machines retaining a player's winnings in the machine for future play.[25]

43. Our analysis of each of these burdens is set out below, first in respect of jackpot machines and then in respect of higher-value AWP machines. The Government does not intend to amend the law in respect of lower-value AWP machines.

Burden (a): methods of payment into and out of gaming machines

44. The effect of the 1968 Act is to designate coins as the only means of payment into, and out of, jackpot machines and higher-value AWP machines.[26] Section 26(1)(b) of the 1968 Act requires all gaming machines to have "a slot or aperture for the insertion of money or money's worth in the form of cash or tokens."[27] The proposal would amend this provision by removing the requirement for jackpot and higher-value AWP machines to have a slot to accept coins or tokens.

45. In respect of jackpot machines, the Department believes that the 1968 Act imposes a burden on operators by requiring such machines to operate solely by means of coins. Section 31(3) of the 1968 Act provides that coins alone may be inserted into a jackpot machine in order to play a game on the machine. Sections 31(4) and 31(5) provide that the only prize which may be delivered by the machine shall be in the form of a coin or coins.[28]

46. The proposal would remove the requirement that jackpot machines can accept payment, and pay out prizes, only by means of coins, by :

  • removing the overall requirement in section 26(1)(b) of the Act that gaming machines must have a slot for the insertion of cash
  • amending section 31(3) so as not to specify that payment into the machine must be in coins, and
  • removing the requirements in section 31(4) and (5) that prizes must be delivered by means of coins.

47. The proposal would instead enable such machines to accept payment for games by means of banknotes in addition to coins, as well as by other "non-cash media" such as a smartcard (referred to in the draft order as "an object capable of being inserted into the machine to pay for a game or games"). It would also enable machines to pay out money prizes in a variety of means other than by coins, that is, by banknote, by cheque, by a credit to a smartcard, or by a credit note or token or other means.[29]

48. Although the consultation paper specified the forms in which payment of winnings from a jackpot machine might be made, namely "banknotes, smartcard credits, a cheque or a credit note or token redeemable in full by the operator",[30] the proposal does not prescribe the specific forms of non-cash payment which may be made into or out of a jackpot machine. The Department argues that "exhaustively specifying" such forms of payment may inadvertently exclude an acceptable means of payment or may "unnecessarily constrain" future technical development.[31]

49. The Department's identification of the burden imposed by the current legislative requirements, and the means it proposes for removing it, both appear to be sound. We conclude that the removal of the requirement that jackpot machines must receive payment in coin, and pay out winnings in coin, constitutes the reduction of a burden on the operators and the players of jackpot machines.

50. In respect of higher-value AWP machines, the Department argues that the burden is contained in section 34(5B) of the 1968 Act, which provides that the maximum charge for play on a higher-value AWP machine shall be the same as that on a lower-value AWP machine. Section 34(2) of the 1968 Act provides that the maximum charge for one game on a lower-value AWP machine shall be "one or more coins or tokens inserted into the machine of an amount or value not exceeding . . . 30p."[32]

51. The 1968 Act does not specifically rule out payment of winnings from higher-value AWP machines in means other than coins, although the wording of section 34(5C) prevents the payment of winnings in tokens. However, the Department believes that if the machine may receive coins alone as payment for play, then in practice it will pay out prizes only in coins.[33]

52. The Department considers that the proposal would remove a burden by enabling higher-value AWP machines to accept payment by banknotes in addition to coins. The proposal would not enable the payment of prizes in any medium other than cash. Such machines would therefore not be able to accept payment via smartcards or pay out prizes by cheque, smartcard credit, credit note or token.

53. We have identified a drafting issue in relation to the way in which the proposal purports to lift this burden. The proposal is intended to allow higher-value AWP machines to accept banknotes in addition to coins, but not to accept smartcards. However, it appears that the proposal, if made, would not have this precise effect, and could in fact allow smartcards and even credit cards to be inserted into the machine as payment. This issue is addressed at greater length at paragraphs 156 to 160 below.

54. We nevertheless conclude that the Department's identification of the burden in current legislation appears to be sound. Subject to a satisfactory resolution of the drafting issue which we discuss below, we conclude that the removal of the requirement that higher-value AWP machines must receive payment in coins, and pay out winnings in coins, constitutes the removal of a burden on the operators and the players of such machines.

Burden (b): accepting payment for a single play

55. The effect of section 31(3) of the 1968 Act, in relation to jackpot machines, and sections 34(5B) and 34(2) of the Act, in relation to higher-value AWP machines, is to require that such machines must be able to accept a coin or coins up to the value required for a single play.[34] At present the maximum payment for a single play of a jackpot machine is 50p, while the corresponding maximum for a higher-value AWP machine is 30p.

56. The Department has not explicitly set out why it believes that this legislative provision constitutes a burden on operators or players of jackpot and higher-value AWP machines, although it does state in passing that it believes the relaxation of the burden will benefit the industry financially.[35] The March 2001 consultation document stated that "requiring machines which accept smartcards and banknotes to provide for players to insert sums of 30p or 50p in coin would be redundant and needlessly expensive for manufacturers and operators."[36] This appears sufficient to demonstrate that sections 31(3), 34(2) and 34(5B) of the 1968 Act impose a burden on operators and players of both types of machine.

57. The proposal would remove this burden by removing the requirement that all gaming machines falling within the scope of Part III of the 1968 Act must have a slot or aperture to accept coins or tokens. One effect of the removal of this requirement is that operators will be able to operate jackpot machines which may accept banknotes and smartcards only, and higher-value AWP machines which may accept banknotes only.

58. We considered a further issue in this respect. The initial consultation document proposed that Gaming Board guidelines should retain the requirement that jackpot and higher-value AWP machines which were to be operated by coins only should continue to be able to accept payment for a single play.[37] The Government now considers that it would not be appropriate for the Gaming Board to reinstate in its guidelines the effect of a legislative provision which Parliament would have removed by means of this order, and that in any case "it would not serve much purpose for the Board to do so." The Department's change of heart is discussed further at paragraphs 99 to 104 below in relation to necessary protections, and in paragraphs 145 and 146 below in relation to consultation.

59. It appears to us that the Department's identification of the burden and the means whereby it is to be removed is sound. We conclude that the removal of the requirement that jackpot machines and higher-value AWP machines must be able to accept separate payment for a single play constitutes the removal of a burden on gaming machine operators.

Burden (c): retention of winnings in gaming machines

60. The wording of sections 31(4), 31(5) and 34(3), and 34 (5C) in the 1968 Act means that prizes won in one session of play on a gaming machine must be paid out at the end of that session, and cannot be retained in the machine for future play. The proposal would amend the law in respect of jackpot machines to enable players to retain their winnings in the machine after a session of play.

61. The Department did not set out in the explanatory statement, nor in the consultation document, why it believed the present requirement constituted a burden, and on whom the burden fell, although it indicated in passing that it believed the removal of the requirement would benefit the industry financially.[38]

62. Consequently we asked the Department to specify the nature of the burden it considered was imposed by the present requirement that prizes won in one session of play on a gaming machine must be paid out at the end of that session, on whom it considered the burden fell, and how the proposal would reduce or remove the burden.

63. The Department has indicated that the burden falls on persons potentially liable for prosecution if they operate gaming machines in a manner which is not compliant with the existing law (for example, operating machines which retain winnings for future play). This requirement on operators constitutes a burden as set out in the Regulatory Reform Act.

64. The Department has also explained the practical effect of the burden imposed by the law: it results in additional wear and tear on a gaming machine's coin-handling mechanisms, and requires players who wish to replay their winnings to reinsert the coins they have won.

65. We conclude that the Department has satisfactorily demonstrated that the proposal would remove a burden by removing the requirement that gaming machines must pay out their winnings rather than carrying them over for further play.

New burdens to be imposed by the proposal

66. The Department indicates that the proposal will create one new burden, which will fall on operators of jackpot machines. It intends to require operators of jackpot machines which pay out through non-cash media (that is, smartcards, tokens or other as yet unspecified means) to redeem these for cash or cheque (or a combination of the two) on demand on the premises where the machine is used.[39] The Department believes that this will safeguard payments to customers by ensuring that "players are readily able to ascertain the amount of any winnings in media other than coin and to claim it in cash or cheque on demand at the premises where they have won it." The Department considers that this requirement would also result in practical benefits to players, who would be able to receive potentially large money wins in non-coin form.

67. We note that the Government does not at present propose to make it a specific offence for an operator to refuse to honour a legitimate smartcard credit. The Department argues that this is because gambling debts are unenforceable in law (a provision of the Gaming Act 1845). It indicates that reform of this aspect of gaming law is beyond the scope of the present order, although it is likely to be reformed via the forthcoming Gambling Bill. This point is dealt with in greater detail in the context of necessary protections at paragraphs 92 to 98 below.

Requirements to be imposed by non-statutory means

68. The Department envisages that the operation of the new machine and smartcard systems will require further customer safeguards. It proposes that these safeguards should be provided by the means of Gaming Board guidelines for the suppliers and distributors of gaming machines. Such guidelines would be non-statutory and non-binding, although the Government argues that they can be effectively enforced by the Gaming Board, which issues certificates of fitness to gaming machine suppliers (but not to operators).[40] Without such a certificate a gaming machine supplier cannot lawfully operate.

69. The proposed guidelines which the Board intends to operate in respect of the new machine and smartcard systems are set out at annex A to the explanatory statement. The Department considers that these guidelines will impose further requirements on the suppliers of new machines, in that they will make detailed rules about the operation of such machines. The Department describes these new requirements as new burdens. However, they are not to be imposed by means of the order, and do not depend on legislation. They are discussed in greater detail in the context of necessary protections at paragraphs 106 to 133 below.

New burden: proportionality

70. Section 1(1)(c) of the Regulatory Reform Act provides that a regulatory reform order may impose a new burden, but that that burden must be proportionate to the benefit which is expected to result from its creation. The Department argues that the new requirement which is to be imposed by the proposal provides a necessary safeguard for users of gaming machines.

71. We were not satisfied with the Department's assessment in the explanatory statement of how the draft order met the proportionality test. The Government's assessment of the test related to the entirety of the new burdens which it proposes should be imposed, by means of non-statutory guidelines issued by the Gaming Board as well as by means of the draft order. We therefore asked the Department to provide an assessment of how the new burden to be included in the draft order would meet the proportionality test without reference to the Gaming Board guidelines.

72. In response, the Department identified the benefit which would arise from the new burden to be imposed by the draft order, namely that a player using a smartcard or other non-cash means to play a jackpot machine would be able to recover any money won or any credit stored on a smartcard. It also considered that the benefit which the proposal would bestow on the operator from being able to run jackpot machines which use smartcards would be proportionate to the new burden to be imposed on the operator.

73. We are satisfied that the Department has demonstrated that the new burden is proportionate to the benefit which is expected to result from its creation.

New burden: fair balance and desirability

74. Section 3(2) of the Regulatory Reform Act provides that a proposal may create a new burden only if:

  • the provisions of the order, taken as a whole, strike a fair balance between the public interest and the interests of the persons affected by the burden being created (section 3(2)(a)), and
  • the extent to which the order would also remove or reduce other burdens, or have other beneficial effects for those affected by current burdens, makes the order desirable (section 3(2)(b)).

75. The fair balance and desirability tests are relevant here because the proposal would create a new burden.

Section 3(2)(a): fair balance

76. The Department argues that the removal of the burdens it has identified would have important financial benefits for the gaming machine industry. To recap, these burdens are:

a) the restriction on methods of payment,

b) the requirement to accept payment for a single game, and

c) the prohibition on retention of winnings in a machine.

77. The Department has set out how it believes the proposal meets the fair balance test.[41] Those affected by the new burden would be machine operators and players. Machine operators, it argues, are prepared to support a change in the law, as the new burden would arise from the wider freedom they would have to configure their machines in a more efficient way. Players would be placed in an advantageous position by the new burden since they would in practice be able to secure payment of any non-cash winnings on demand.

78. The Department also considers that the public interest would be served, as far as operators and players of machines are concerned, by an increase in the efficiency of operation of gaming machines. The public interest would additionally be served by the inclusion in the proposal of protections intended to ensure that machines are operated in ways which do not risk encouraging players to use them excessively. It therefore believes that the provisions of the draft order strike a fair balance between the public interest and the interests of persons affected by the burden being created.

79. The protections against excessive use contained in the proposal are material to the Department's assessment of how the draft order meets the fair balance test. However, they are not contained in the draft order, but in the accompanying Gaming Board guidelines. We have considered whether the operation of the proposed Gaming Board guidelines will sufficiently maintain necessary protections. Our specific findings in relation to necessary protections are set out at greater length below.

80. We conclude that the proposal strikes a fair balance between the public interest and the interests of the operators and players of gaming machines.

Section 3(2)(b): desirability

81. The Department indicates that the Government believes the proposal is desirable because it would offer estimated benefits to the gaming machine industry of £1.85 million a year. The Department believes that the proposal would also offer "some benefits" to players, but it does not set out what they are in the body of the explanatory statement. The Regulatory Impact Assessment attached to the explanatory statement states that the anticipated benefits to players are as follows:

. . . more choice in methods of playing machines and [the receipt of] prizes in a more convenient form. [Players] would also benefit from fewer machines down time and fewer disputes if the machine does not pay out properly.[42]

82. Although the Government has not stated here that the proposal also removes one or more burdens, we are satisfied that the draft order would do so. We therefore conclude that the extent to which the order removes or reduces one or more burdens, or has other beneficial effects for persons affected by the existing law, makes it desirable for the order to be made.

Continuing necessary protections

83. The Department did not initially set out its view of whether the existing law affected by the proposal afforded any necessary protection and, if so, how that protection was to be continued. This gave us no firm basis for assessing the extent to which the protections in the proposal and in the proposed Gaming Board guidelines continue any necessary protections. We therefore asked the Department to list the protections which it considered were contained both in present legislation and in current Gaming Board guidelines on the operation of gaming machines, to indicate the extent to which it considered these protections would be continued by means of the order and the proposed new guidelines; and to indicate, in respect of any protections which are not to be continued, whether it considered they were necessary.

84. In its response the Department set out the three protections which it believed were contained in the present legislation, namely:

a) The fact that players must pay for games in coin. As the highest-value coin in circulation at present is £2, this in effect means that players must make a separate decision to commit each sum of up to £2 to play.

b) The fact that players of jackpot machines are paid out in cash when they win.

c) The requirement that machines must be able to accept payment for a single play. The provisions of the 1968 Act relating to jackpot machines and higher-value AWP machines both require that "the charge for play for playing a game once by means of the machine shall be a coin or coins of an amount not exceeding [value]".

Protection (a): payment for games in coin

85. The present requirements in the 1968 Act are that jackpot and higher-value AWP machines may accept only coins in payment, and may pay out only by means of coins. Whether or not these provisions were intended as protections when the legislation was first enacted, they appear now to operate as forms of protection for the users of such machines.

86. The requirement in sections 26(1)(b), 31(3), (4) and (5) and 34(5D) of the 1968 Act that payments into the machine may be made only by means of coins prevents users of gaming machines from committing more than the maximum value of a single coin (at present £2) to play at any one time, and therefore provides a protection against committing larger sums of money to play in a single action. A separate action is required to insert each coin, which gives the player opportunity for reflection. We note that there is at present no legal limit to the number of coins which may be inserted into the machine at any one time, and there is no requirement for operators to pay out unused coins.

87. The Government proposes to continue protection (a)—which has the effect of setting the maximum payment into a machine at £2—by means of Gaming Board guidelines, which will require machines accepting banknotes or smartcards to be programmed so that players must make a fresh decision to commit each separate tranche of £2 or less from their smartcard, inserted banknote or winnings to play the machine.

88. This protection will not be continued in legislation, but the Department considers that this provision is "entirely equivalent to what currently exists" in legislation. The existing law does not define £2 as the maximum payment which may be inserted into a machine in order to play. The Department nevertheless believes it appropriate that there should be an upper limit equivalent to the highest value coin in regular circulation. One consultation response called for a £5 upper limit (equivalent to the lowest-value banknote in general circulation), a suggestion the Department rejected.[43]

89. We agree that, wherever a player is able to insert large sums of money into a gaming machine, there ought to be an upper limit on the amount the player is able to commit to play at any one time. We believe that this upper limit ought to be equivalent to the highest-value coin in general circulation (at present £2), and that in principle the limit ought to be expressed thus in Gaming Board guidelines.

90. We have considered whether provision for this necessary protection ought in fact to be included on the face of the draft order, rather than in Gaming Board guidelines. We have concluded below that the Gaming Board will be effective in the administration and enforcement of the guidelines which will accompany the draft order. We are therefore prepared to allow the Department the flexibility to make provision for this form of protection by means of guidelines, and believe that the limit should be expressed as proposed above.

91. We are content that this necessary protection should be continued by non-statutory means.

Protection (b): immediate payment in cash

92. At present the player of a jackpot machine is in effect guaranteed to receive all winnings in cash, because of the requirement that such a machine may pay out only in coins. Although there is no specific requirement for a higher-value AWP machine to pay out winnings in coins, the Department argues that in effect they do so, as they may at present accept only coins. Thus for both types of machine the player is in theory guaranteed an immediate payout of winnings, as the present legislation does not allow winnings to be carried over for further play. The Department has, however, noted that while the 1968 Act defines the maximum prizes which gaming machines may pay out, it does not require operators to pay them.[44]

93. This protection is to be continued in respect of non-cash media by means of the new burden in the draft order: that is, the requirement that operators running jackpot machines which pay out in non-cash media should pay out the full value of a player's winnings on demand by cheque, cash or a combination of the two at the premises where the machines are used for gaming. The consultation document indicated that the Government did not propose to make it a specific offence for an operator to refuse to honour a legitimate smartcard credit, but that "a consistent pattern of improper refusal to settle smartcard credits would plainly have an impact on the operator's market."[45]

94. We have considered whether the requirement for operators of jackpot machines to pay out winnings in full by cash or cheque is an adequate continuance of the protection which the operation of coin-only machines presently provides. In doing so, we took into account the response to the consultation document from Cardiff University Law School, which argued that the protection which the proposal provided for the consumer in respect of smartcard redemption was insufficient. A mere requirement on an operator to pay out a smartcard credit would not be enforceable, as under the Gaming Act 1845 gambling debts are not enforceable in law, and the threat of market sanctions against an operator who failed to pay out on a smartcard would depend very much on the operation of the market in the operator's area. It believed that if operators were to be given the commercial advantages of the use of smartcards, their obligations to players should be set out in law.

95. In response the Department has argued that the level of protection provided to players who win prizes which are to be delivered from machines by non-cash payment methods is equivalent to the protection presently afforded to players who win cash prizes: "there is no significant difference so far as the player is concerned between being paid out in cash directly by a machine and being paid out by non-cash means which are redeemable on the premises."[46] We note that in fact the level of protection is slightly increased, since there is at present no explicit requirement on operators to pay cash prizes (for example, in situations where a machine does not have sufficient coins to pay out a prize).

96. It is intended that the forthcoming Gambling Bill will repeal the provisions of the Gaming Act 1845, and will establish a process whereby gambling debts are enforceable through the civil courts. The Department conceded that it would be possible to disapply the 1845 Act from gaming machine smartcard debts, and to make it a criminal offence to refuse to pay out on a smartcard credit. However, to include such provisions in the draft order would be disproportionate in the overall context of the present law on gambling, and would create a situation where relatively small smartcard debts would be legally enforceable, while larger debts in connection with betting or casinos would not be.[47]

97. The Department has set out more fully why it believes that the operators of jackpot machines would in any case be unlikely to refuse to pay out on a legitimate smartcard credit. Operators of casinos and bingo clubs need a magistrate's licence to operate, and are subject to Gaming Board monitoring. Should these operators refuse to pay out on smartcard credits won on jackpot machines on their premises, the Department argues that the Gaming Board would have to consider applying to the magistrates for cancellation of their licence. Operators who run jackpot machines in members' clubs need magistrates' permits to operate their jackpot machines. The Department believes it improbable that they would refuse to pay out on a gaming machine prize won by a member or a guest, and that if this were the case members could have recourse to a club's own procedures.[48]

98. The present level of protection for players of gaming machines is not perfect: there is no present requirement in law on operators to pay out cash winnings from a machine. As we note above, the level of protection provided for payment from machines by non-cash means is in fact slightly higher than that provided for in existing legislation. We are therefore satisfied that a necessary protection is continued in this respect.

Protection (c): payment for a single play

99. Protection (c) is not to be continued. The Department does not consider this protection to be a necessary one: "it does not add to consumer safeguards to have law which requires that players must always be able to insert, in effect, their loose change into a gaming machine".[49]

100. In removing the requirement that jackpot and higher-value AWP machines should be able to accept payment for a single play, the proposal would remove a form of protection for users of these machines. At present, if they wish to, players can limit the stake they commit to the machine to that required for a single game. Under the proposal, machines which accepted smartcards and/or banknotes would no longer be required to accept the minimum stake: the proposed Gaming Board guidelines might require players to commit as much as £2, unrefundable, to a higher-value AWP machine which can charge no more than 30p for a single play.

101. The Home Office, in its consultation document, initially proposed to retain the protection in Gaming Board guidelines, but in the explanatory statement the Department indicated that it was not to be retained, as it was "redundant and needlessly expensive" for machines which were designed to accept smartcards and/or banknotes to have to accept payment for a single play. When we asked why the requirement was to be dropped from Gaming Board guidelines, the Department explained that on reflection it was not considered "necessary or logical to require coin-only machines to accept payment for a single play when machines taking banknotes do not", and that the issue should be a commercial matter for the industry to decide.[50] The proposal would also remove this requirement from machines which could continue to accept coins. Operators will therefore decide whether they wish to retain machines which can accept payment for a single play in order to attract casual players.

102. GamCare (the National Association for Gambling Care, Educational Resources and Training), in its response to the consultation, stated that it believed the requirement to accept payment for a single play was "an important safeguard, especially for the occasional or casual player." It nevertheless understood the reason for removing the requirement, and raised no objection to it, on the understanding that relevant machines would display clearly the minimum stake which had to be committed to play the machine, together with the number of games which could be played for that stake.

103. The Department's stated intention is that "the player should always easily be able to know how much it will cost to play on the machine."[51] The Gaming Board is not aware of any machine which does not show the price of a game on its face, and the Department states that it has never been necessary to set such a requirement. Once the requirement that all machines should be able to accept payment for a single play is removed, however, the amount which a player will have to insert into a machine to play a game will in many cases be more than the price of a single game. We consider that if it is the Department's intention that the player should always easily be able to know what it will cost to play on the machine, it should take this issue into consideration. We nevertheless agree with the Department in its overall assessment of the protection.

104. We agree with the Department that the present protection in respect of accepting payment for a single play is not a necessary one, and may be dispensed with.

105. We are therefore satisfied that the proposal would continue all necessary protections.

Protections to be contained in Gaming Board guidelines

106. Apart from the new protection to be included in the draft order (discussed at paragraphs 93 to 98 above), all other safeguards on the operation of the proposed new types of machine are to be enshrined in proposed Gaming Board guidelines. The Department believes that the guidelines are needed "to ensure adequate safeguards for customers." [52] It believes that it is more appropriate to include these safeguards in guidelines, as they are easier to adapt to circumstances "in the light of a rapidly-changing, high-tech industry."[53]

107. A draft of the guidelines is available at annex A to the explanatory statement. The Department states that this draft is "broadly in its final form" but may be subject to minor changes before coming into effect. The Department has assured us that he guidelines will be in their final form when the draft order is laid for final scrutiny.[54] They are to be issued under the authority of the Gaming Board, which will discuss any amendments to them with the Department before such amendments are issued.

108. The safeguards which the Department indicates are to be implemented by means of Gaming Board guidelines will include:

  • a specification of £20 as the maximum denomination of banknote which may be used in a gaming machine
  • a requirement that a player cannot transfer more than £20 credit from a smartcard to a machine without having to remove and reinsert the card
  • a requirement that gaming machines using banknotes or smartcards be programmed so as to require players to make a fresh decision to commit a sum of up to £2 from their banknote, smartcard or winnings credits to playing the machine, every time the amount on the play meter falls below the minimum charge for a single play
  • a requirement that players who decide not to commit a fresh sum of up to £2 to playing the machine are subsequently able to retrieve all the money owed them by the machine, with the proviso that the machine may be able to retain sums of up to £1, which may be used for further play or (if insufficient for a single play) retained for use by subsequent players
  • a requirement that players with credit on the play meter less than that required to play a single game are then able to collect all money owed to them by the machine (subject to retention in the machine of sums of up to £1).

109. The Department also indicates that the Gaming Board's present guidelines for the operation of AWP machines prevent players of machines being able to accumulate more than five times the maximum prize from the machine. This restriction is to be continued.

110. The guidelines which the Gaming Board presently issues to the gaming industry are not subject to parliamentary control, although amendments to them are discussed with the Department before they are made. The proposed guidelines which are to be issued with the draft order are similarly not to be subject to parliamentary control. The Department argues that the proposals "do not significantly alter the overall balance" between the statutory protections to be delivered by means of the draft order (which it describes as "core protections") and the non-statutory protections to be assured by means of the Gaming Board guidelines.[55]

111. We have considered above the issue of the protection in the existing law concerning the maximum sum a player may commit to play a machine at any one time. We are content that it should be continued by means of Gaming Board guidelines, as the Department proposes. Therefore we agree with the Department's analysis that the proposal adequately maintains the present overall balance between statutory and non-statutory protections. Our concerns over the provisions of certain individual protections to be included in the guidelines are set out below.

Automatic credit to smartcard

112. The consultation paper indicated an additional safeguard to be included in the Gaming Board guidelines, namely a requirement that whenever a smartcard is withdrawn or ejected from a gaming machine, the machine shall first credit the card with all the money owing to the player.[56] This requirement does not appear in the list of proposed guidelines in the explanatory statement. The Department's analysis of consultation responses indicates that two consultees—the British Casino Association and Gala Leisure—had argued that this requirement would disrupt players' playing patterns.

113. The Department has explained that, on reflection, it considers this requirement to be technically impractical, given the other requirements applying to the operation of smartcards. If a player emptied a smartcard of value, it would be automatically ejected, but would first have to have all the value recredited to it: it would therefore be impossible for a player to commit the full value of a smartcard to play on a machine.

Provision of smartcard readers

114. The explanatory statement indicated that Gaming Board guidelines would provide for premises which have gaming machines to have smartcard readers separate from such machines for customers to use to check the amount remaining on a smartcard without inserting it into a gaming machine. [57]

115. The draft of the Gaming Board guidelines attached to the statement states that "a facility must be available on the premises which will show the player what credits his smartcard holds without requiring credits to be spent or a game to be played. In practice, this requires that this facility is provided by the machine, where the contents of the smartcard will be shown on a display until either the player transfers money from the smartcard or withdraws the smartcard."[58]

116. We asked the Department to explain the discrepancy between the explanatory statement and the draft guidelines. In response the Department stated that it did not now think a separate smartcard reader was necessary, as "it is better for the player to have a reader conveniently sited in the machine he is playing."[59] It also explained that the Gaming Board could exert more direct control over smartcard readers sited in machines, as the Board could exert more direct control over suppliers, and through them over manufacturers: if a manufacturer produced a machine which the Board did not like, it could exert its influence over machine suppliers not to use it or site it.

117. We note that it would in any case have been difficult for the Gaming Board to enforce any guidelines on the provision of smartcard readers on the operators of gaming machines, as the guidelines are addressed to suppliers and not to operators.

118. We are nevertheless concerned that the Department appears to have reversed its position on a provision in the proposal which appeared to constitute a valuable safeguard for the player. Although the draft Gaming Board guidelines require a smartcard reader to show a player the amount of credit on the card without requiring credits to be spent or a game to be played, it is entirely conceivable that manufacturers might construct machines which would invite or induce a player to transfer credit or to play a game as soon as a smartcard was inserted into the machine. We believe that this would be an unacceptable development and would reduce the level of protection available to the player. We believe that the draft Gaming Board guidelines should be amended so as to provide that a player who inserts a smartcard into a gaming machine shall not receive any inducement or invitation to play a game on the machine unless and until the player has committed money to play.

Retention of surplus credit

119. The Department envisages two situations where Gaming Board guidelines will allow a gaming machine to retain a player's money in the machine:

  • where the amount on the play meter is less than that required to play a single game, and
  • where the amount on the bank meter is less than £1 (enabling the machine to pay out from the bank meter in round pound amounts).

120. The provision that a machine is not required to pay out a sum on the play meter which is less than the stake required for a single game is, the Department states, in line with present Gaming Board guidelines on the operation of gaming machines: "there are often occasions when a small amount of money, not enough for a single game, is left in the machine."[60] We accept that in this respect the present level of protection is therefore retained.

121. The provision that amounts of less than £1 can be retained on the bank meter is of greater concern to us. The industry might argue that it is more convenient for payouts from the bank meter to be made in round pound amounts, and this may make practical sense for machines which pay out prizes in coins. The Department argues that the provision is acceptable, since, once the requirement on machines to accept payment for a single play is removed, machines which accept only £1 or £2 coins will not have lower value coinage to pay out smaller amounts.[61]

122. At present, therefore, it appears that the retention of small cash residues in a gaming machine is tolerated because machine design renders it impractical to pay them out in full. Electronic means of payment are not, however, affected by this mechanical impediment. We believe that technological developments in the gaming machine industry ought to work to the consumer's benefit. Accordingly we see no good reason why, in principle, players using jackpot machines which can accept and pay out value by electronic means should not be able to collect the full value owing to them on the bank meter at any reasonable time. We would expect the Gaming Board guidelines to reflect this principle.

123. It would in any event be open to operators of smartcard-enabled machines to decide that it is in their interests to set their machines to make full payment from the bank meter to a smartcard, thereby encouraging the use of smartcards and attracting players from cash-only to smartcard-enabled machines.

124. We asked the Department whether it believed that the retention of small sums on the bank meter of a gaming machine might constitute an inducement to a player to continue playing the machine. The Department told us that the player protection issue was whether the player had to pay for that further play, and argued that at present players with cash residues left on a machine could insert coins to make up the difference between the residue and the amount required for a single play. It therefore believed that the draft order would introduce nothing new.

125. New sections 31(3A), (3B) and (3C), to be inserted by the draft order, provide for the use of smartcards in jackpot machines and for their redemption. Section 31(3B)(c) provides that any payment by the operator to redeem a smartcard must be of the 'appropriate amount'. Section 31(3C) defines this amount by means of a formula, (A+B)-C, where A is the amount paid for the smartcard, B is the amount of any prize to be credited to the card and C is the amount charged for one or more services where the card has been used to pay for those services. Such services would include play on a jackpot machine, and might also include play on other amusement machines or the purchase of food or drink.

126. Where a smartcard is used to play a gaming machine, and is then offered for redemption, it therefore appears that the card must be redeemed in accordance with the formula ('cost of credits to card' plus 'winnings') less 'amount paid for play' (which will presumably always be a multiple of the charge for a single play). This does not appear to allow any leeway for a machine to retain any cash residue on the play or the bank meters when a smartcard has been used to play the machine. An operator running smartcard-operated machines which were set to retain cash residues of less than £1 on the bank meter might therefore risk a breach of the law. We draw this matter to the Department's attention.

Retention of winnings in gaming machines

127. The requirement in the 1968 Act that gaming machines must immediately pay out a player's winnings in full appear to constitute a form of protection for the player. While the proposal would remove this requirement, the Department proposes to replace it with a requirement in Gaming Board guidelines that winnings shall either be paid out directly or credited to the bank meter for the player to collect or transfer to the play meter as wished.

Enforcement of existing and proposed Gaming Board guidelines

128. The Department acknowledges that the Board's guidelines are non-statutory and non-binding, but argues that they can nevertheless be effectively enforced, as Schedule 6 to the 1968 Act empowers the Board either to revoke a certificate issued to a person who sells, supplies or maintains gaming machines, or to decline to renew it, if it considers that the holder of the licence is 'not a fit and proper person'. The Department indicates that the Board "regards its guidelines as covering matters which can be taken into account in assessing whether a certificate holder is fit and proper", and that this view has been tested successfully in the courts.

129. Certificates under section 27 of the 1968 Act are issued to gaming machine suppliers by the Gaming Board for periods of five years, and are renewable. The annual report of the Gaming Board for Great Britain for 2001-02 states that there were 678 certificates in force in Great Britain on 31 March 2002.[62] Of the applications decided in the financial year 2001-02, one application for a new certificate was refused by the Board. No certificates were revoked, and no applications for renewal were refused, although the holders of 18 certificates due for renewal during the year did not apply for renewal.

130. We asked the Department to provide an analysis to cover the last three financial years for which figures were available of the Board's activities in certifying suppliers and refusing and revoking certificates: its response is set out in Appendix B.[63] The Department states that breaches of the guidelines are extremely rare, and are normally dealt with by discussions with the supplier or the manufacturer of an offending machine. The ultimate sanction is the removal of the supplier's licence. The Department has also demonstrated how it believes the Gaming Board guidelines, which are addressed to suppliers, can be enforced upon operators.

131. In its response to the Government's consultation, GamCare raised a number of issues relevant to the operation of the Gaming Board's guidelines. GamCare believed that the enforcement powers of the regulatory authorities should be improved, stating that "despite the assertion in the consultation document, it is our understanding that the regulator's powers to enforce compliance are only partly effective."[64] It also believed that certificates of fitness should be issued to operators of gaming machines, as well as suppliers.[65]

132. In response to our invitation to elaborate on its concerns over the Board's enforcement powers, GamCare stated that its principal concern in this respect was in the illegal siting of higher-value AWP machines in areas which could be accessed by minors, a licensing issue which it accepted was out of the Gaming Board's hands.[66] While this issue is clearly of some concern, it is not directly relevant to the matter before us, which is the Gaming Board's ability to enforce its guidelines on the suppliers of gaming machines. The Department recognises that in some instances Gaming Board control can be brought to bear only indirectly, but it considers that in this instance the Board's powers will be effective.[67]

133. We are satisfied that the Gaming Board will be effective in the administration and enforcement of the guidelines which will accompany the draft order.


134. The consultation document relating to the proposal was issued by the Home Office (the department then responsible for gambling matters) on 19 March 2001, and published on the Home Office website. Responses were invited by 15 June 2001. The consultation began before the Regulatory Reform Act had received Royal Assent, and consultation therefore took place under the provisions of the Deregulation and Contracting Out Act 1994. The Home Office indicated in its consultation document that the consultation was intended to satisfy the requirements of the Regulatory Reform Bill should it be enacted. In the explanatory statement to the proposal the Department indicates that the Government is satisfied that the consultation has satisfied the requirements of section 5(1) of the Regulatory Reform Act.

135. Fifty responses were received to the consultation, mainly from individual gaming machine suppliers and operators, representative bodies (for example, BACTA, the operators' trade association), churches and religious organisations, charities with interests in gambling, and academics. The Department has summarised the responses in the explanatory statement (paragraphs 113-152).

136. A sizeable majority of the consultation responses, from all sectors consulted, welcomed the proposed changes insofar as they enabled the appropriate and efficient use of modern technology in gaming machines. A number of responses did, however, raise issues in relation to problem gambling which were not adequately covered in the Department's explanatory statement, and we have raised these with the Department.

Problem gambling

137. A number of consultees pointed out that spending virtual cash (that is, credits on a smartcard) rather than real cash would mean there was less of a psychological barrier to excessive spending.[68] This might in turn lead to an increase in problem gambling on gaming machines, possibly exacerbated by the actions of unscrupulous suppliers and operators.

138. The Department indicated that, while the Government's aim was to require all parts of the gambling industry to operate to the highest standards of social responsibility, it was beyond the scope of the order to enshrine this requirement in law. However, it envisaged that a new Gambling Commission, to be established by the proposed Gambling Bill, would be responsible for issuing codes of practice on social responsibility which would form part of operators' licences. It noted that the gambling industry was making encouraging progress in setting up a trust to pay for the treatment of problem gamblers and to commission research into the causes of problem gambling.

139. The consultation document stated the Government's concern that the proposed changes should not exacerbate problem gambling. It indicated that it "seem[ed] unlikely" that players' playing patterns would alter. In support, it cited two assertions made by the gaming machine industry: that 70 per cent of winnings on gaming machines, normally smaller winnings, were replayed into machines (based on analysis of data collected by the manufacturer JPM in the course of a research exercise); and that most players would decide in advance the limit to their session expenditure (based on a poll of leading gaming machine operators conducted by BACTA). The Department believed that the proposed changes would be unlikely to alter this pattern of behaviour.

140. The consultation response received from Cardiff University Law School observed that the consultation paper made no reference to the Gambling Prevalence Survey, undertaken by the National Centre for Social Research, the results of which were published in 2000, which it stated was the only recent large scale sample which tested problem gambling, although it did not capture specific data about players' turnover on machines. Contrary to expectations, the survey had found that gaming machines were not the worst temptations for problem gamblers.

141. The response of the Centre for Research into the Social Impact of Gambling based at the University of Plymouth, noted the Government's assertion that the proposed changes would not exacerbate problem gambling. It stressed that it was "absolutely imperative" that research should be undertaken to address the potential impact of the changes, both on the patterns of consumption of gaming machine users and on their likely effects on problem gambling behaviour, prior to the changes being made,

142. We asked the Department whether it had commissioned, or was aware of, any independent research into the likely effects of the new machines and payment methods on player behaviour and problem gambling. The Department responded that it had commissioned no specific research on the draft order, as it would be difficult to carry out in advance of the changes being made. It noted that the Gambling Review Body had reviewed a wide range of research evidence before it had endorsed the proposed changes. A review of this research evidence carried out by independent consultants for the Gambling Industry Charitable Trust had indicated that machines could be configured to increase the risk of excessive play, but that there was no evidence to suggest that there were significant risks in allowing players to insert value into machines in one form rather than another.[69]

143. We recognise that it is difficult to simulate the effects on player behaviour of gaming machines which cannot yet lawfully be operated in Great Britain. But we do not necessarily share the Department's confidence that the new machines will not pose any significant additional risks to player behaviour. We consider that the Department should arrange for an independent monitoring programme to assess the effects of the new machines on player behaviour, to report the results of the monitoring programme to the House and to take appropriate action should it appear that the new machines are exacerbating problem gambling behaviour. The monitoring programme should be rolled forward to cover the operation of the new machines covered by this proposal under the similar provisions which the Department indicates will be enacted via the Gambling Bill.

Changes to proposal following consultation

144. The Department states that there have been no changes to the proposal as a result of representations received following consultation.

145. The Government, in its consultation document, proposed to include in Gaming Board guidelines the requirement that those jackpot and higher-value AWP machines which did not accept smartcards and/or banknotes (that is, ones which would continue to be coin only) should remain capable of accepting payment for a single play. In the explanatory statement, the Department explains that it had dropped this requirement from the proposal because it believed that it would be inappropriate for Gaming Board guidelines to re-impose a provision which had been removed from legislation by Parliament, and that in any event it would not serve much purpose to do so. We have addressed the Department's arguments in this respect at paragraph 101 above.

146. The Department states that as the substance of the issue of accepting payment for a single play had already been raised in the initial consultation document, it believed that to drop the requirement in the case of coin-only machines did not raise any separate issues, and it did not therefore believe that any new issue of principle had arisen which would have required re-consultation on the proposal.[70]

147. We are satisfied that the proposal has been the subject of, and taken appropriate account of, adequate consultation.

Costs and benefits

Financial costs and savings

148. The Department identifies costs to the industry which will arise from operators either converting their machines to accepting notes (a cost of between £250 and £300 per machine) and smartcards (£170 per machine). BACTA consider that operators wishing to have the full benefit of the new methods of play will have to purchase new machines: these are likely to cost in the region of £2200, compared to £2000 for a current machine. These initial costs to the industry would reduce the immediate benefit of the proposals in year one, but the Department considers that they would soon be absorbed in subsequent years.

149. The Department indicates that the overall financial benefits to the industry will be delivered in the form of:—

  • reduced maintenance costs (owing, for example, to coin jams)
  • reduced down times (that is, when a machine is out of action)
  • fewer engineering visits to machines
  • reduced disruption when altering stake or prize limits or introducing new coins
  • improved money handling and cash flow procedures for operators; and
  • increased efficiencies for manufacturers who presently manufacture machines for the domestic and European markets.

It states that 49% of faults on jackpot machines are coin-related, either on acceptance or at payout,[71] and notes that it is much easier and quicker for operators to deal with banknotes and smartcards than with coins.[72] We note, however that in its consultation response GamCare countered the assertion that the new machines would be more reliable than the old coin-operated machines. It believed that the more complex the methods of payment into and out of a machine were, the greater the likelihood of machine breakdown.

150. The Department believes that as a result of the proposal, players will be able to receive prizes in a more convenient form.[73] The consultation document notes that the current top prize of £1000 (since amended to £2000) for jackpot machines operated in licensed casinos must be paid out in coins from the machine itself, and that a payout in this form may significantly burden the mechanism of the machine.[74]

151. We have noted above the substantial variance between the overall benefit to the industry estimated in the March 2001 consultation document—£9.5 million annually—and the estimated benefit of the proposed order, which is now set at £1.85 million, or less than 20% of the initial estimate. The Department explained that this drastic revision has come about because the proposal cannot now allow the use of smartcards, payouts in means other than coins, or the optional retention of winnings for future play, in higher-value AWP machines. The industry has expressed its frustration that the proposed reform of the law applying to jackpot machines cannot at present be fully extended to higher-value AWP machines.[75]

152. We asked the Department why, given the very significant reduction in overall benefits which the proposed order will now achieve, the Government has decided to press ahead with the draft order at this time and in this form. As noted above, the Department believes that there is no reason not to proceed now with "a modest package of reform that will immediately deliver small, but real, advantages to the industry".[76] The Gambling Bill is expected to implement wider reforms, including those originally envisaged in the consultation paper.

Other benefits

153. The Department believes that there will be benefits to gaming machine players, who will have more choice of machines, may experience greater reliability in machines paying out and who will be able to receive prizes in a more convenient form. It also identified potential benefits to machine suppliers and operators in the event that the United Kingdom adopts the euro, as operators of note-only machines would not have to have their coin acceptors replaced.

154. We asked whether gaming machines in Great Britain are at present able to accept payments in euro, and/or to pay out in euro, and whether the proposal would make any difference to these arrangements. The Department and the Gaming Board "consider it (at the least) highly probable" that current legislation allows machines to accept payment and pay out prizes in euro or other currencies subject to the sterling maxima in the 1968 Act, and they do not believe that the present proposal would alter the position.[77]

155. A regulatory impact assessment is at annex B of the explanatory statement. On the basis of this and the other information provided by the Department, we are satisfied that the proposal has been the subject of, and taken appropriate account of, estimates of increases or reductions in costs or other benefits which may result from the implementation of this proposal.


156. The explanatory statement indicates that, in relation to higher-level AWP machines, the proposal is intended to enable them to accept only coins and banknotes, and to pay out only coins and banknotes. The Department states that machines would not be able to accept money by means of any medium other than cash. But it is by no means clear that the draft order, if made, would amend the 1968 Act in this way.

157. The draft order would amend section 26(1)(b) of the Act to remove the requirement for jackpot machines to accept coins only and for higher value AWP machines to accept coins and tokens only. It would also amend subsections 34(5B) and (5D) to remove the requirement that higher-value AWP machines should accept and pay out by means of coins only. The draft order does not, however, specify what means of payment may be made into a higher-value AWP machine. It appears that the effect of the proposal, if made, would in fact be to enable higher-value AWPs to accept any form of payment, extending to smartcards and even to credit cards.

158. The explanatory statement made it clear that this outcome is not intended. We therefore drew the point to the Department's attention. The Department responded that while, at present, higher-value AWP machines are not prevented from accepting tokens as payment, in practice no machines do accept tokens in payment, as they must pay out a money prize. Even though the requirement that these machines must accept only coins or tokens in payment will be removed once section 34(5B) is amended, the requirement in section 34(5C)that the machine must deliver a money prize will remain. The Department therefore argues that in practice higher-value AWP machines will still be able to accept payment for play only by means of coins and banknotes, and not by smartcards or any other non-cash means.

159. We are not persuaded by this analysis. The Department has accepted that there is in effect a small loophole in the law, which may be enlarged once the draft order is made. It argues that the effect of the law is in practice determined by the mechanical operation of machines, and appears satisfied that the situation will not change should the draft order be made.

160. In our view, the effect of the draft order, if made, would be to leave an already complex and unclear piece of legislation even less clear than before. We find it difficult to understand why the Department should not seek to tighten the drafting of the order in order to remove the possibility that credit cards may be used for payment. This is a purely technical amendment which will have no effect on the substance of the proposal and will provide greater clarity. We therefore recommend that the draft order be amended so as to stipulate that higher-value AWP machines may accept only coins and banknotes as payment for play.

19   Fourth Report of the Deregulation Committee, Session 2000-01, The Final Deregulation Proposals, HC (2000-01) 450 Back

20   Ibid., para 50, footnote 25 Back

21   Ibid., para 51 Back

22   Explanatory statement, para 19 Back

23   Contained in sections 26(1)(b), 31(3), (4) and (5) and 34(5D) of the 1968 Act Back

24   Contained in sections 31(3) and 34(5B) of the 1968 Act. Back

25   Imposed by sections 31(4), 31(5) and 34(3), and 34(5C) of the 1968 Act Back

26   Lower-value AWP machines may accept stakes in the form of coins or tokens and pay out prizes in coins, tokens and non-monetary form: explanatory statement, para 42. Back

27   Explanatory statement, para 33 Back

28   Explanatory statement, paras 28-29 Back

29   Explanatory statement, para 40 Back

30   Gaming machines: methods of payment: a consultation paper, Home Office, March 2001, para 54 Back

31   Explanatory statement, para 16 Back

32   Explanatory statement, para 30 Back

33   Explanatory statement, paras 31B32 Back

34   Explanatory statement, para 34 Back

35   Explanatory statement, para 63 Back

36   Consultation document, para 50 Back

37   Explanatory statement, para 130, and consultation document, para 61 Back

38   Explanatory statement, para 63 Back

39   Explanatory statement, para 57 Back

40   Explanatory statement, para 59 Back

41   Appendix B, paras 10-11 Back

42   Explanatory statement, annex B Back

43   Explanatory statement, para 135 (Justices' Clerks' Society) Back

44   Appendix B, para 27 Back

45   Consultation document, para 57 Back

46   Appendix B, paras 17-18 Back

47   Appendix B, paras 25, 22 Back

48   Appendix B, paras 23-24 Back

49   Appendix B, para 20 Back

50   Appendix B, paras 40-41 Back

51   Appendix B, para 39 Back

52   Explanatory statement, para 61 Back

53   Appendix B, para 44 Back

54   Appendix B, para 46 Back

55   Appendix B, para 45 Back

56   Consultation document, paras 52 and 61 Back

57   Explanatory statement, paragraph 68 Back

58   Explanatory statement, annex A Back

59   Appendix B, para 38 Back

60   Appendix B, para 43 Back

61   Appendix B, para 42 Back

62   Report of the Gaming Board for Great Britain 2001-02, HC (2001-02) 1016, pp 52-57 Back

63   Appendix B, para 51 Back

64   Consultation document, para 60: "The [Gaming] Board's guidelines are not part of the law. But it can enforce them effectively." Back

65   The Department has indicated that its proposed Gambling Bill will create a Gambling Commission which will license both suppliers and operators of gaming machines. Back

66   Appendix D Back

67   Appendix B, para 49 Back

68   For example, GamCare, the Church of Scotland, the Methodist Church, the Wesleyan Reform Union, Nottingham Trent University and the Welsh Assembly Government. Back

69   Appendix B, para 58 Back

70   Appendix B, para 60 Back

71   Explanatory statement, para 97 Back

72   Explanatory statement, para 100 Back

73   Explanatory statement, para 102 Back

74   Consultation document, para 36 Back

75   ALegal glitch could delay parts of deregulation order@, BACTA press release, 13 November 2002 Back

76   Appendix B, para 66 Back

77   Appendix B, para 67 Back

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