Supplementary memorandum by Thomas Holdings
Ltd (SP 07A)
I would like to thank you for giving me the
opportunity to appear before your Committee. I hope that you found
my evidence (as well as the written submission) helpful as part
of your inquiry. As a follow-up I thought it might be useful to
expand on a couple of the points I referred to in my oral evidence.
If health is the reason for a smoking ban, it
is illogical for it not to be a total ban; otherwise people will
migrate to venues where they can continue to smoke, making the
situation worse in those venues. A total ban would at least create
a level commercial playing field and limit the migration of customers
In the consultation paper under competition
issues, it is recognised that giving local authorities the power
to decide would lead to problems where customers move from a smoke
free place in one jurisdiction to a smoking place in another jurisdiction.
A partial, national ban would make this situation even worse,
as customers can just move to a smoking place across the road.
The latest draft of figures prepared by the Henley Centre for
the Bingo Association predict that while a total ban will lead
to an overall drop in bingo admissions of around 5%, a partial
ban would lead to a 12% drop in admissions. This difference is
evidence of the likely migration effect of a partial ban. It shows
the direct impact of the proposed exemptions (currently on offer
for competitor establishments such as membership clubs). With
a total ban there is also more likelihood that customers lost
initially would return.
Our customers are, principally, mature
women who are happy with the product we offer and enjoy being
able to come to a mature, safe environment. They do not want to
have to go to places like working men's clubs, but will do so
if they can continue to smoke there.
There are 19,000 registered clubs in the UKincluding
political, sports, snooker, factory and working men's clubs. A
partial ban will concentrate the smokers in these venues, all
of which will still be able to serve hot food and admit children.
This will not only undermine any distinction of "food"
or "not food", but will expose these clubs' customers,
their families, children and their employees to even more harm
by making their environment worse.
Whilst a total ban will undoubtedly have a negative
economic impact on our businesses, phasing-in will at least allow
our customers more time to get used to the idea of a smoking ban,
and for bingo halls and other venues to gently persuade them by
extending the areas that are smoke free on a gradual basis. This
is why we support delaying the introduction of a ban until 2009.
I hope you find this additional information
useful. It is, as I explained before the Committee, the view of
the companies listed below. Do not hesitate to contact me if you
require any additional information.
6 November 2005