Memorandum by the Bingo Association (SP
48)
1. Bingo, with its 525 clubs which we represent
and its three million regular players, has a unique place in the
gambling sector. Licensed bingo clubs form an integral part of
the social fabric of communities nationwide. In very many small
towns, they provide the only leisure activity where women, who
comprise about 75% of bingo players, can go by themselves in total
safety.
2. If a ban is to be imposed, our members
believe it should be total. A smokefree policy should be based
on the principle of equal treatment across all sectors. If the
basis for a ban is health-related, this is the only logical position
to adopt, and is consistent with the approach taken in Scotland,
Northern Ireland, and likely in Wales. The proposal to exempt
specific types of clubs from the general ban defies logic because
employees in exempt clubs are equally at risk from secondhand
smoke as are employees in other types of clubs. According to the
Government's own document a partial ban is likely to lead to a
40% reduction in benefits compared with a total ban. The partial
Regulatory Impact Assessment does not seem to have allowed for
the displacement of smokers from non-smoking venues to those where
it is still permitted.
3. The proposed exemptions, which would
not include licensed bingo clubs, would simply lead to massive
displacement as our players moved to clubs and pubs where smoking
was still permitted. These premises can legally offer bingo up
to a threshold of £2,000 per week, which is not subject to
any form of taxation, and would provide a parallel gaming environment.
The Government has failed to address the issue of displacement
in the Regulatory Impact Assessment. Licensed bingo clubs would
suffer significant economic hardship and this is highly likely
to lead to the closure of many smaller clubs which will deprive
large numbers of our customers of the opportunities and enjoyment
provided by commercial bingo.
4. Any form of smoking ban will have a significant
economic impact on licensed bingo clubs, particularly since nearly
50% of our players smoke, much higher than the proportion of the
population as a whole. The industry recognises the Government's
position on the health benefits of a ban, and accepts that one
is inevitable.
5. A widely-applied smokefree policy should
have very limited exceptions, which should not include the hospitality
and leisure industries. However, if the policy is to include the
wider-ranging exemptions contemplated in Option 4 in the White
Paper then commercial bingo should be included in those exemptions.
To maintain the current range of exemptions would be unfair and
anti-competitive.
6. The proposals contained in the Choosing
Health White Paper are a confused mixture of policies attempting
to keep all sectors on board and reflecting a vague notion of
"public opinion" but in practice discriminating against
some premises in favour of others. The proposals will produce
a law applying differently in England to the rest of the United
Kingdom.
November 2005
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