Memorandum from The Scottish Licensed
Trade Association (DGB 2)
The Scottish Licensed Trade Association welcomes
the opportunity to submit the following comments on the Draft
Gambling Bill and confines such comments to the issue of gaming
machines and AWP machines in liquor licensed premises.
The Association was formed in 1880, is the only
body representing all sectors of the Licensed Retail Trade in
Scotland and with 2,198 members, is recognised by many as the
voice of the Licensed Trade in Scotland.
The Association has three core functions—trade
development, trade protection and trade liaison. The Association
works with, and in many cases has representation on, various groups
such as the Criminal Justice Forum; Excise Alliance; Local Authorities;
Liquor Licensing Boards; Scottish Tourism Forum and many more.
The SLTA has formed a close working relationship with The Scottish
Executive and is consulted on all issues concerning the Licensed
Trade in Scotland. A representative from the Association sat on
the Nicholson Committee, formed to review the Scottish Liquor
Licensing Laws and propose changes.
The Association is still very much concerned
that it would appear that public houses, "pubs", will
be greatly disadvantaged and will see little benefit from the
proposals, compared with other entertainment premises which could
substantially benefit. In fact members of this Association are
already experiencing a significant decline, up to forty per cent,
in income from AWP machines. In our opinion this has been due
to the extreme restrictive conditions and payouts imposed on public
houses, when compared to licensed betting shops and registered
clubs.
This is extremely worrying, as many Liquor Licensed
Premises depend on such income as an integral part of their business
survival.
AWP machines are a part of the traditional leisure
facilities offered within the Licensed Trade. These premises have
unjustly been singled out. To be thrown the meagre crust of "allowing
pubs to keep what they have", with perhaps a few minor benefits,
is no comfort whatsoever to the Licensed Trade. Casinos, bingo
halls, and betting offices would appear to have the opportunity
for widespread liberalisation of AWP machine facilities.
This is anti-competitive and does not attract
support from "pub" customers and the general public.
Over the years, the services provided by the
Liquor Licensed Trade have been "poached" by other establishments,
and it is about time, the balance was redressed. For example,
betting shops now have AWP machines and can serve food and soft
drinks. How long will it be before they are permitted to serve
alcohol?
With regard to the protection of children, the
Licensed Trade already operates in a very strict and controlled
environment. The members of this Association do not perceive that
there is a problem with under 18s playing AWP machines in Licensed
Premises, but would suggest that Registered Clubs should have
far stricter controls. Individuals under 18 can play in these
premises, where the jackpot is far higher than that in Licensed
Premises and very often there is little or no control over this.
In fact, we would question that if a Registered Club is considered
as "an extension of one's home", would one really have
an AWP machine in his or her own dwelling.
We would also suggest in fact, that if the current
restrictions on AWP machines in Liquor Licensed Premises is maintained,
the subsequent effects will not be welcomed by Local Authorities
in Scotland. The Licensed Trade is one of only two groups that
differ in the method of calculation of Local Authority Rates compared
with other business sectors. Business Rates for Licensed Premises
are calculated on turnover and all income, including that from
AWP machines, is taken into account. By maintaining the restrictions
on AWP machines in "pubs", which has already led to
a significant drop in revenue, and curtailing the opportunity
for extra revenue from these premises, the Government will in
effect be reducing the income to Local Authorities through business
rates.
In the interests of fair competition and non-discrimination,
we would advocate that the payout levels for AWP machines should
be the same in "pubs", Registered Clubs and Licensed
Betting Shops. Members of The Scottish Licensed Trade Association
are simply asking for parity with other entertainment establishments
in order to survive in this extremely competitive market.
December 2003
| 
