Memorandum from the British Casino Association
(DGB 57)
1. INTRODUCTION
1.1 The British Casino Association (BCA)
represents the interests of the operators of over 90 per cent
of the 125 casinos in Great Britain.
1.2 We welcome the draft Bill. However,
in seeking the social and economic benefits, which could arise
from the development of large casinos, the Government plans to
impose unnecessary and anti-competitive restrictions on existing
casinos. We believe that the three adjustments listed below could
be made without prejudice either to those benefits, or to the
Bill's overall objectives.
2. THE ADJUSTMENTS
WE ARE
SEEKING
2.1 The ratio of table games to machines
The Ratio of eight machines per table recommended
by the Budd Committee had a logic based on an average table having
eight playing positions, thus maintaining a 50/50 balance between
machines and table gaming.
The Government has now said that it "is
inclined to the view" that this ratio should be reduced to
three in small casinos but it has offered no objective criteria
for this suggested reduction. The BCA therefore believes that
a ratio of eight machines per gaming table still represents a
balance between table gaming and machines.
However, the Government has stated that this
limit would be kept "under review in the light of advice
from the Gambling Commission about its operation and effect".
As the BCA considers that this ratio should be greater than three,
if the Scrutiny Committee is not persuaded to support a higher
initial ratio, the BCA requests the Committee to recommend that
the Government to commit itself to an early review (say within
12 months) of this low ratio with the intention to increase it,
if there are no adverse social consequences arising from the initial
deregulation.
2.2 Allow machines to be linked between
casinos
We believe there is no research evidence that
the size of the prize is a key factor in encouraging problem gambling.
If so, it would be illogical to allow 1,000 plus machines to be
linked in large casinos, and to continue to allow linking between
bingo clubs and for progressive stud poker games between casinos.
The Budd Report stated in para 23.66 that "linking with other
small operators could be the most effective way for a small operator
to compete with a big casino, which could on its own offer large
prizes without linking with others. If the Government remains
concerned about the scale of linking, a limit could be set of
500 machines linked together in one arrangement. It is already
unusual for more than 500 machines to be linked in foreign casinos.
We also believe that the issue of linking should be delegated
to the Gambling Commission.
2.3 Limit large casinos to 1,000 machines
We consider that the jump from a maximum of
120 machines in a casino having 40 tables, on a gaming floor of
10,000 sq ft or less, to an unlimited number at 10,000 sq ft is
too great a leap. Unlimited machines should be reserved for premises
of regional significance (resort casinos). All other large casinos
should be limited to under 1,000 machines.
3. DUTY AND
TAX
Nobody can assess the future viability of a
casino until the future tax and duty regime has been resolved.
The existing structure will deter inward investment.
December 2003
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