Supplementary memorandum from the Casino
Operators Association of the UK (DGB 104)
During Evidence on 15 January 2004 the subject
of the COA(UK) proposals on table/gaming machine ratios came up
and the suggestion was made that it be written into the evidence.
I promised to let you have a note for your committee.
The COA(UK) feels strongly that the 1:3 ratio
flies in the face of all previous proposals and understanding
that it would be an 1:8 ratio—including the concurrence
of GamCare, DCMS and the Gaming Board. Further, because of the
low numbers of tables (40) after which the ratio moves towards
infinity, the fairness of competition between small casinos and
large ones would be radically removed. Consumer choice would also
be reduced because small casinos, favoured by many punters at
present for their convenience and hands-on customer relations
by management and staff, would be driven out of business because
of the overwhelming influence of machines. (Save, as we discussed,
specific niche or boutique small operators.)
To raise the "unlimited" barrier by
raising it to 62 tables, and at the same time affording a smoother
progression on machine numbers relative to tables, we proposed
to the Minister DCMS the following:
— grandfather rights be implemented;
they should also include the right to expand the table gaming
floor area up to 5,000 sq ft if they so wish;
— thereafter the 5,000 square feet
minimum table games area be introduced exclusively for table games.
It would not be necessary to fill the area with tables but neither
should it be utilised for other elements such as machines, bars,
bingo, entertainment etc;
— above 5,000 and up to 10,000 square
feet the area must contain the minimum 5,000 square feet dedicated
to tables but thereafter the remaining area may be utilised in
a mix at management's discretion to meet their specific market;
— if the casino wishes to deploy a
table gaming area in excess of 10,000 square feet, then the first
10,000 square feet must be filled with tables at the average table
area of, say, 160 square feet each ie 62 tables. Again the remainder
may be utilised at management discretion;
— at the above three levels the table
to machine ratio should be at the 1:8 level until the nominal
62 table level is exceeded when it moves to unlimited. This would
have the effect of moving the onset of unlimited machine casinos
from 40 tables to 320 machines to 62 tables to 496 machines—large
enough for any major investment short of resort/destination casino
size where a minimum of 1,500 machines may be expected;
— all tables to be manned at manning
levels capable of proper operation. The purchase of tables alone
should not provide the basis of meeting table to machine ratios;
— the role of the Gambling Commission
in the planning process be again considered. There would appear
to be a continuing advisory role of which planning should take
account. The strengthening of those powers in certain circumstances
to a mandatory function seems necessary if a national overview
is to be sustained.
One final point on the attractiveness of machines
in extremely large numbers to the commercial equation for resort
casinos. There was, I thought, an implied inference during evidence
that the machines were not so important because the other facilities/attractions
were profit centres in their own right. We totally disagree; the
machines are core to the operations and without them the entrepreneurs
involved would not contemplate the project. And, wearing my Gordon
House Trustee hat, machines in such numbers will inevitably bring
problem gambling clients in greater numbers to our doors.
In summary, we return to the COA(UK) mantra—expansion
by all means, but only by controlled, measures progress capable
of straightforward retrenchment should it go wrong. The current
draft Bill does not meet that fundamental requirement, good though
much of it may be.
January 2004
|
