Supplementary memorandum from the Casino
Machine Manufacturers Group (DGB 158)
I believe you approached Phil Thomas, the UK
Sales and Marketing Director of Novomatic, at the ICE Show in
London and asked him to write regarding Novomatic's position on
machine numbers in small casinos. Novomatic is a member of the
Casino Machine Manufacturers Group (CMMG), and supports the Group's
position on machine-table ratios. As a result, Mr Thomas has passed
your query on to me to deal with.
As stated in our written evidence to the Committee,
we submit strongly that the machine to table ratios should not
be specifically defined within the Bill from the outset and that
power conferred on the Secretary of State in accordance with clause
140(10) should be utilised to define permitted machine numbers
by way of regulation in the first instance. Such an approach is
consistent with the policy objective of allowing for a controlled
evolution in the choice of gambling products.
As to the most appropriate machine to table
ratio, we stated in our submission that we would encourage the
Committee to consider the various submissions of operator companies
with an interest in the issue. After listening to the evidence
given to the Committee and consulting widely with casino operators,
the CMMG has created a proposal regarding machine numbers, which
we have attached.
I hope that you find our proposal of interest.
If you have any further questions please do not hesitate to contact
me.
MACHINE NUMBERS
IN CASINOS
The maximum number of gaming machines permitted
in accordance with subsection (3) is eight times the number of
gaming tables, with three exceptions:
(a)
Casinos with table gaming areas of not less than
10,000 square feet, a minimum of 40 table games, and non-gaming
area not less than 50 per cent of the gaming area should be permitted
to have a machine gaming area of up to three times the table gaming
area.
(b)
Casinos with table gaming areas of not less than
10,000 square feet, a minimum of 40 table games, and non-gaming
area not less than 100 per cent of the gaming area should be permitted
to have a machine gaming area of up to four times the table gaming
area.
(c)
Casinos with table gaming areas of not less than
10,000 square feet, a minimum of 40 table games, and non-gaming
area not less than 300 per cent of the gaming area should be permitted
to have an unlimited machine gaming area.
(See appendix A for definitions)
JUSTIFICATION
Given that the average table in a casino has
eight playing positions, the CMMG believes that a ratio of eight
machines per table, as recommended by Budd, would be logical.
This ratio maintains a fifty-fifty balance between machine and
table gaming, thus preventing casinos becoming dominated by machine
gaming. In addition, we believe that this ratio, combined with
the minimum size requirement of 5,000 square feet of table gaming
space, will be sufficient to prevent proliferation.
Through combining these two ideas, it will be
possible to prevent the "cliff-edge" between having
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 10,001
sq ft. Instead, casinos will be able to have 320 machines, unless
they meet the size requirements of "large" casinos,
and provide alternative activities to gambling on the premises.
When the first requirement is met, casinos will still be faced
with a limit of 1,000 machines, with the next limit being at 1,333
machines. In order to be allowed unlimited machines under our
proposal it will be necessary to provide a non-gaming area three
times the size of the gaming area. (See appendix B)
We believe this proposal will create a significant
incentive for operators to develop "resort" style casinos,
with restaurants, bars, shops and other amenities. By linking
the number of machines allowed to the size of the non-gaming area
it is possible to create a significant impetus for the development
of casinos with regeneration potential—something which is
notably lacking in the Draft Bill as it stands.
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