Memorandum from St Saviour's Church (DGB
32)
1. GUILDFORD
CHURCHES
1.1 Guildford's churches cover a broad spectrum
of mainstream denominations, representing roughly 6,000 people
(ten per cent of the population). We are upbeat, flourishing and
actively involved in our local communities. Numerous cross-church
initiatives run youth work, social and pastoral care schemes.
Eighty per cent of volunteer work is undertaken by people with
a Christian motivation. Surrey Police have recently given a special
award to Guildford Diocese for operating the "Appropriate
Adult" scheme for vulnerable people in custody. Voluntary
sector provision for the homeless in Guildford is provided entirely
by the churches. Over 30 youth workers in Guildford are funded
by church organisations, listening to and investing in young people.
1.2 St Saviour's Church, in the town centre,
has led on this issue for geographical reasons.
2. GUILDFORD'S
STORY
2.1 Guildford demonstrates the characteristics
of "successful" Surrey—a vibrant economy, attractive
environment and many affluent residents. Thousands of students
attend the University, Law College and other further education
establishments, then stay to take advantage of excellent employment
opportunities. In a busy leisure industry, the night-time economy
has expanded considerably over the last 10 years, attracting hundreds
of young people from a wide area, to clubs and pubs, as well as
classic cultural pursuits such as theatre and music. The nearest
casinos are in Reading, Portsmouth and London.
2.2 Guildford has its problems, however.
In economic terms, the town centre is congested with an infrastructure
struggling to cope in a "gap" town where geographical
expansion is limited. Housing is a huge problem: mortgage burdens
are colossal and many people are over-committed. Affordable housing
is in short supply. There has been particular dissatisfaction
with the development of mega-pubs in a small area on our traffic
gyratory system, and the increase in alcohol-related disorder
which Surrey Police have been stretched to get under control.
All social agencies complain of notorious underfunding in "leafy"
Surrey and struggle to meet their objectives. Churches are keenly
aware that Surrey conceals pockets of utter social deprivation
and attendant addiction problems. Family and relationship breakdown,
together with intense work stress, add considerably to social
distress across the economic spectrum. Divorce rates are high.
Even behind the tree-lined drives, there is a lot of quiet desperation.
3. EXPERIENCE
OF CASINO
PLANNING APPLICATIONS
3.1 In early 2002, the owner of a prominent
town centre nightclub submitted a planning application for a massive
nine-floor casino in the heart of the clubs and pubs. The scheme
represented a considerable expansion in numbers of people in the
area, enabling customers to arrive for a nightclub, but flow easily
onto gaming tables or slot machines. The proposal was strongly
opposed on planning grounds by the Borough Council and numerous
local bodies, and on public disorder grounds by Surrey Police.
It was refused and subsequently failed on appeal after a public
inquiry. A second similar scheme on the site has just been unanimously
refused on the grounds of over-development.
3.2 Two other local hotels also submitted
casino applications. On planning grounds, one was refused and
the other finally achieved consent. The latter scheme entailed
conversion of existing conference facilities with a good record
in planning terms.
3.3 Local churches objected strongly to
all the above, on both planning and social grounds, at each formal
stage. Having researched the effect of deregulated gambling upon
places with experience of this, we had a number of concerns about
not only the particular buildings but also the impact of their
activities on our local community.
3.4 Our frustration lay in wrestling with
the serious limitations of planning legislation when addressing
social impact. "Impact on residents" is interpreted
to mean people who reside or work within sight or sound of the
building concerned or travel past it. We have had numerous debates
with planning officials who are obliged to follow professional
guidelines on what lies within their scope and what does not.
3.5 In consulting local social agencies
informally (such as probation, community workers, social services),
we discovered that they usually accept the logic that a gambling
development is likely to augment social problems, and ultimately
add to their burden. However, professionals in these agencies
are unwilling or unable to comment publicly on a specific planning
application.
4. OUR SOCIAL
CONCERN
4.1 As regards the wisdom of deregulating
gambling, we fully endorse the submissions made to the Committee
by the Methodist Church, the Salvation Army and the Evangelical
Alliance, where detailed assessments are made of the social risks
of problem gambling and the effect of the proposed legislation.
4.2 Guildford churches are fully convinced,
by common sense and the available research, that greater access
to gambling will inevitably increase the frequency of problem
gambling. We are anxious about the adverse effect upon our town
of this increase. We fear:
— a rise in family and marital tension
leading to divorce;
— a rise in problem gambling among
children and young people, particularly where multi-use leisure
facilities and casinos are in close proximity for young people
to drift into if poorly controlled. Low-stake Category D slot
machines are a particular worry;
— a rise in public disorder in places
where it is already barely manageable. Associating alcohol and
gambling is unhelpful; alcohol impairs both judgement and the
life skills people need for responsible decision-making;
— an escalation in debt. People across
the economic spectrum are already living close to the edge. Gambling
and debt cause people to fall out of the net very rapidly. Acute
housing difficulties will follow;
— increased public health problems
such as stress, depression and mental health difficulties where
gambling is out of control;
— a rise in crime fuelled by people
having to fund addiction;
— acute social distress rippling out
from problem gamblers to their relatives; and
— extra burden upon the local social
agencies such as social services, councils, police and probation.
4.3 The economic arguments concern us. We
sense there might be a slump in Guildford's excellent business
and environmental reputation if it becomes a casino centre. Guildford
does not need the low-grade jobs a casino might offer, and struggles
to fill all the employment opportunities it has, due to housing
costs. We are convinced that the argument for revenue generation
is false. Regeneration is not a need of ours, but research shows
that casinos will impact negatively on local businesses such as
restaurants. We would like to see Guildford making much better
use of the wealth it has.
4.4 We advocate much tougher legislation
on the Codes of Social Responsibility for gambling operators,
including ways for them to demonstrate their implementation of
the codes and penalties if these are breached. We also feel that
casinos offer huge potential for sophisticated money laundering
and we would like to see a seriously effective tax regime that
will discourage evasion and remove criminal opportunity.
5. PLANNING,
LICENSING AND
SOCIAL SERVICES
LEGISLATION
5.1 Experience of wrestling with the system
leads us to propose some constructive changes. In the end, social
theory is expressed in bricks and mortar and individual planning
applications. This is where the legislation will really bite.
Where is the scope for local communities to comment fully upon
the impact of particular developments? Planning officials must
be required to interpret impact on residents in a broader sense,
not just those within sight or sound of the building.
5.2.1 We propose that:
Applicants for planning and licensing consent
for gambling premises be required to notify a wide range of interested
parties with a stake in community building, across the geographical
area from which the applicants expect to draw their customers.
These parties could include: social services, police, probation,
all single or multiple addiction treatment bodies, primary care
trusts, community workers, hospitals, schools, churches and all
faith and community groups. Any inclination to limit this notice
to a narrow local area should be resisted, especially as some
of these services are provided on a regional or county basis.
5.2.2 Planning regulations should be amended
to extend the bodies included as statutory consultees. Amending
statutory instruments to the Planning Acts would be relatively
straightforward. If planning officials are already required to
consult interested parties such as the Highways or Environment
Agencies, why not also Social Services? Such a move would free
social agency professionals to comment neutrally and independently,
with regard to research, on the social science case. This is similar
to the police responsibility to comment on the crime implications
of particular developments. For practicality, it might be necessary
to limit statutory consultation on social grounds to applications
with potential impact on addiction issues, or of a large scale
nature.
5.2.3 Statutory consultees on the social
impact could include most of the interested parties listed in
5.2.1. We are sufficiently confident of the social case to leave
it to the professionals to advise. Local agencies know the strength
of their local social infrastructure. Those with experience of
handling families broken by addiction will not find it impossible
to measure the impact of further addiction possibilities. In the
Government's Green Paper "Every Child Matters", multiple
social agencies are encouraged to work together and develop preventative
strategies to identify and address the key drivers of poor outcomes
for children. Substance misuse is the single greatest cause of
children being placed on child protection registers. Problem gambling
is often associated with multiple addiction problems and merits
equal treatment when assessing social disadvantage. The statutory
duty to comment on relevant planning applications would represent
a new departure for social agency professionals, but is entirely
in keeping with a more holistic "joined-up" multi-agency
approach.
5.2.4 The above must also apply to planning
applications for change of use—whether town centre or out
of town.
5.2.5 At the very least, a mechanism must
be found to enable social professionals to be consulted and to
comment formally on relevant planning applications with a risk
of negative social impact.
5.2.6 When considering mega-casinos, regional
planning authorities should also be required to take into account
the dangers of proliferation in problem gambling, as well as regeneration
potential.
6. RESEARCH
6.1 We believe further research on the prevalence
of problem gambling right now in the UK is urgent and essential
to enable the impact of deregulation to be monitored.
7. CONCLUSION
7.1 Churches are not kill-joy. We believe
in life in all its fullness. Guildford people work extremely hard
and are entitled to enjoy high quality leisure facilities—but
in a safe environment where the risk of addiction is sensibly
controlled.
7.2.1 Churches are deeply committed to community.
We live with the same social stresses and brokenness as everyone
else. We gladly do all we can to alleviate social distress and
will continue to do so, but part of our social commitment is arguing
for prevention as well as cure. It is less painful and cheaper
all round to legislate problems out, not in. We feel the deregulation
of gambling should be undertaken with much more caution, in smaller
steps.
We would be happy for one of us to speak to
the Joint Committee in person if you wish it.
Thank you for giving this your consideration.
December 2003
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