Memorandum from Premier Bowl (DGB 179)
My specific points are:
1. The majority of tenpin bowling centres
in the UK have alcohol licences in place which means that, under
the current draft legislation, they will be treated as pubs. Clearly
the design, style of operation, target market and product offering
of the UK's 300 plus tenpin bowling centres are radically different
to that of a pub.
2. Tenpin bowling centres operate, on average,
more than 17 Type C & D gaming machines (numbers at each centre
vary between two and 100+) whose contribution to the economic
viability of the business is critical.
3. It is not certain that existing tenpin
bowling centres will be provided with Grandfather Rights because
only the Policy Memorandum (note 7) covers this issue and not
the main Draft Act. Local Authorities are not obliged to consider
the Policy Memorandum in their deliberation.
4. Clauses 21 and 34 of the draft legislation
would require tenpin bowling centres to seek permission from the
Local Authority for extra machines (over the two machines which
will be automatically granted under a liquor licence). Clause
236 then applies conditions for the granting of permission for
these extra machines.
5. The 8th condition of Clause 236 is that
children and young persons are excluded from participation. This
would mean that tenpin bowling centres would not be able to provide
pushers, cranes and other category D machines for use by under
18s, unlike family entertainment centres which remain completely
unrestricted.
6. I understand that the guidance to Local
Authorities is likely to identify that tenpin bowling centres
are expected to have more than two gaming machines. However, this
leaves tenpin bowling operators exposed to Local Authorities setting
their own policies irrespective of guidance, which is not an uncommon
occurrence. I do not believe that any of the other categories
of gaming are exposed in the same way as pubs and bowling centres
are to a Local Authority policy decision.
March 2004
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