Memorandum from the British Association
of Leisure Parks, Piers and Attractions Ltd (BALPPA) (DGB 72)
INTRODUCTION
The Association, established in 1936, represents
the interests of 118 theme and amusement parks, and piers, accounting
for almost 100 per cent of that sector of the Attractions Industry.
Our Membership consists of privately and family owned and operated
facilities, many of which have been passed down over several generations.
They provide amusement and entertainment for
the family market, principally in the socio economic groups of
Cl, C2 and D. These groups make up a significant proportion of
the British families who continue to holiday, enjoy short breaks,
and days out in the U.K.This point being particularly relevant
in relation to some of the new restrictions proposed in the Draft
Gambling Bill.
DRAFT GAMBLING
BILL
We have found the Draft to be lacking in detail
in a number of important clauses. Following the publication of
the Policy Instructions earlier in the year, we had anticipated
the Draft Bill would contain specific proposals reflecting that
Document and the submissions made in response.
In consideration of the above, and in compliance
with the request for brevity in response, we have referred primarily
to the points referred to in Clause 193: Gaming machines: categories
A to D. Based on our understanding that this clause is likely
to contain the detail to which the Policy Instructions referred,
we make the following comments.
In addressing the issue of maximum stakes payable,
the Policy Instructions referred to a proposed freeze on 10p stake
and £5 prize for Category D machines. Should this be included
in the Bill it will not allow businesses to recover any increased
cost which may result from changes in taxation, minimum wage,
increases in utility charges and other expenditure beyond the
control of the operator. We propose that the stake and prize remain
a matter for the Triennial Review currently in operation and which
will we hope be retained.
Value and nature of the prize delivered as a result
of use of a Category D machine
The Policy Instructions proposes that the current
maximum stake of 30p be reduced to 10p and non-monetary prizes
such as cuddly toys be restricted in value to £5, a reduction
from the current level of £8, the exception being cranes
(grabbers) which will retain the 30p stake but still a restricted
prize value of £5. These machines are considered a major
part of the entertainment on offer from coastal locations in particular.
Should these proposals be included in the Bill, machines offering
non-monetary prizes will cease to be financially viable and result
in the removal from the offer available to families who find these
machines not only enjoyable to play but an economic opportunity
to obtain quality gifts for their children as a souvenir of their
visit.
We propose retention of the current level of
30p stake and £8 maximum non-monetary prize value.
Types of premises
Again referring to the Policy Instructions,
it is proposed that our Members who currently operate areas restricted
to over 18s, known as designated areas, will not have access to
the Category B machines in other separately designated areas ie
premises within premises.
The proposal will only allow these machines
in premises to which children do not have access.
We believe criteria for premises within premises,
not accessible from Family Amusement Centres, could be agreed
to allow Category B machines to be operated by our Members. This
would allow locations such as theme parks and piers the option
of operating these machines and allow our Members to compete with
the likely increase in this type of machine in Adult Gaming Centres
and the Fixed Odds Betting Terminals being operated in Licensed
Betting Offices.
Clause 16 Codes of Practice
Given the existence of voluntary codes of practice
within the Industry, we assume these will form the Code proposed
by the Commission and will be produced in consultation with the
Industry.
Protection of Children
We would refer to the suggestion that the Secretary
of State reserves the right to introduce primary legislation to
restrict Category D machines for children under 16.
We propose that such legislation could only
be introduced following Government sponsored research conducted
using a brief agreed with the Industry Associations and in circumstances
which have provided clear evidence that such research is necessary.
We maintain that use of Category D machines
by children not only allows the whole family to participate in
harmless and enjoyable entertainment; it provides an opportunity
to encourage responsible attitudes towards the use of machines.
Grandfather Rights
In conclusion, we seek assurance that the protection
of Grandfather rights will be respected in relation to the ongoing
and future renewal of licenses and permits. The existence of such
rights will require clear explanation to ensure that those charged
with the future responsibility on these matters are clear in the
protection such rights confer on existing businesses.
December 2003
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