Written Evidence to
the Joint Committee
DGB 9
Draft Gambling Bill Consultation:
Response from the Evangelical Alliance
December 2003
The Evangelical Alliance
welcomes the opportunity to participate in the consultation relating
to the draft Gambling Bill.
The Evangelical Alliance, which was founded in 1846,
is the umbrella body that brings together a majority of Britain's
1.39 million Evangelicals. Included in Alliance membership are
over 7000 organisations and churches whose views we aim to represent
in this submission. The 1998 English Church Attendance Survey
revealed that 35% of Anglicans, 87% of Baptists, 78% of Independents,
35% of Methodists, 93% of New Churches, 93% of Pentecostals, 21%
of URC members, 63% of those attending other churches identified
themselves as Evangelicals.
The Alliance exists to promote unity and truth amongst
these churches, individuals and evangelical organisations and
to represent their concerns to the wider Church, State and society.
We seek to work with and through our members rather than to duplicate
or compete with them. Thus, this response seeks to represent the
Alliance in its widest sense and is the product of consultation
amongst specialist member societies.
We also refer you to
the concurrent submission of the Methodist Church: 'Written evidence
to the Joint Committee on the Draft Gambling Bill'. The Evangelical
Alliance endorses this separate submission concerning which the
Methodist Church and the Salvation Army are partners together
with the Evangelical Alliance.
SUMMARY
- INTRODUCTION.
- SOCIAL RESPONSIBILITY
A major consequence of
deregulation has to be serious acceptance of increased levels
of social responsibility by the gambling industry.
- SOCIAL COSTS / LOCAL
VOICES
As gambling expands, so
do its associated problems. Heavy addictive gambling, like drug
use, can lead inevitably to e.g., divorce, domestic violence,
child abuse, and bankruptcy. The Evangelical Alliance recommends
that the Bill takes full account in section 129(a) of the overall
market catchment area in respect of proposed gambling developments.
- RESEARCH
In light of local concerns,
questions relating to the true catchment area of large scale gambling
developments, and the dearth of serious up to date research in
the UK we recommend the institution of baseline research now to
establish foundational statistics on gambling addiction and social
costs.
- PLANNING AND SOCIAL
CONCERN
An overhaul of the local
planning system with regard to new gambling developments is vital
in conjunction with the proposed Bill. We recommend the inclusion
of social agencies such as social and probation services, primary
care trusts, hospitals and addiction treatment agencies and community
workers as well as police forces in the list of consultees.
- CRIME
We welcome as a licensing
objective "preventing gambling from becoming a source of
crime or disorder." There is a need to introduce an effective
system for the serious regular investigation of criminal activity
and potential.
- DEBT
The Evangelical Alliance
is concerned about the general tendency of the Bill to encourage
yet further levels of debt in the population at a time when public
debt has reached crisis proportions. It is especially concerned
to highlight the dangers involved with the use of credit cards
in conjunction with especially internet gambling.
- INTERNET
We recommend that the strongest possible controls
and monitoring systems are put in place to encourage best practice
in respect of on-line gambling. We recommend a British Gaming
Portal with a clear 'kite mark' style approval system.
- NATURE OF GAMBLING INDUSTRY
Research from other nations
that have relaxed their gambling laws suggests that a liberalisation
in the gambling laws will favour large casino developments over
racing and the national lottery.
- CHILDREN AND GAMBLING
The Draft Bill's licensing objectives include: "protecting
children and other vulnerable persons from being harmed or exploited
by gambling." We welcome this commitment in the Draft Bill.
However, we outline some practical suggestions to help ensure
better protection of children and the vulnerable of any age.
- THE COMMITTEE.
We acknowledge the apparent
expertise of the Committee members as the list of members' interests
shows a wide experience of the gambling industry. However we are
concerned that there may be a dearth of experience on the Committee
relating to the social consequences of gambling as opposed to
widespread experience and vested interest in the running of betting
enterprises. We recommend a better balance on the Committee to
ensure it enjoys public credibility.
- CONCLUSION
RESPONSE
- INTRODUCTION
We recognise that modernisation
of the gambling industry is necessary, particularly to keep pace
with technological change. However a major consequence of deregulation
has to be serious acceptance of increased levels of social responsibility
by the gambling industry. It is wholly unacceptable that the costs
of deregulation should involve a massive increase in the numbers
of problem gamblers and associated local and national social impact.
Experience in other countries confirms that a huge increase in
gambling opportunities will inevitably produce a corresponding
increase in problem gambling together with a rise in local anti-social
and environmental effects. Therefore, whilst we welcome some of
the increased protections that are likely to be offered through
legislation, we are concerned that the potential increase in problem
gambling and the need to prevent proliferation of negative anti-social
consequences should remain as a matter of priority at the forefront
of the Committee's deliberations.
- SOCIAL RESPONSIBILITY
We are relieved and pleased
to see that the Government has introduced recognition of the crucial
concept of social responsibility into proposed gambling policy.
Research evidence consistently shows that gambling damages the
mental and physical health, employment, relationships, and family
lives of those whose gambling gets out of control (customarily
referred to as 'problem gamblers') and can leave large numbers
of people and their dependents with massive debts. Social responsibility
involves gambling operators taking unquestioned responsibility
for the harmful impact that gambling has on many people. It includes
realistic contribution towards the treatment and support of problem
gamblers, but also encompasses business practices, research and
education necessary to counter increases in problem gambling.
It has been encouraging to see the proposed establishment
of the Gambling Industry Charitable Trust, and their intention
to raise appropriate contributions from sections of the gambling
industry. However, the Trust must be, and must be seen
to be, independent of the industry, or its role and its research
will be discredited in the public eye. Whilst the figure of £3
million represents a welcome starting point, we would remind the
Committee that this amount equates to a mere £10 per problem
gambler according to the British Gambling Prevalence Survey, and
therefore represents not only an unrealistic contribution compared
to the size of the potential problem, but also a relatively minute
proportion of anticipated gambling profits. We support the Government's
decision to establish whether a voluntary trust is an appropriate
mechanism, and strongly recommend that the clear threat of a levy
be held in reserve. However, the gambling operators who refuse
to contribute and ride on the backs of those who do are clearly
already creating a problem. The Joint Committee may wish to suggest
that adequate contributions to the Trust, or another approved
organisation supporting problem gamblers, should be taken as evidence
towards compliance with the social responsibility conditions necessary
for the grant of an operating licence.
- SOCIAL COSTS / LOCAL
VOICES
We recognise that the Government
now acknowledges the risks inherent in the deregulation of the
gambling industry. They have recognised the need for close industry
regulation to maintain high standards, deter crime, and protect
children and the vulnerable. We welcome measures intended to fund
a gambling trust to address problem gambling - but this also raises
questions relating to the very nature of gambling as an appropriate
subject for industrial enterprise expanded on this scale.
As gambling expands, so
do its associated problems. Heavy addictive gambling, like drug
use, can lead inevitably to a string of interrelated adverse social
consequences, e.g., divorce, domestic violence, child abuse, and
bankruptcy. According to a 1998 study commissioned by the National
Gambling Impact Study Commission, residents within 50 miles of
a casino are twice as likely to be classified as 'problem' or
'pathological' gamblers than those who live further away ('The
Bookie of Virtue' by Joshua Green, editor of The Washington
Monthly).
The Evangelical Alliance
recommends that the Bill takes full account in section 129(a)
of the entire market catchment area when proposed gambling developments
are being considered. It is simply not good enough to have regard
only for those who live "sufficiently close to the premises
to be likely to be affected by the authorised activities."
Thus, for proposed national
or international gambling resorts, a complete national remit should
apply. It is hoped that the Committee clearly recognises that
a Las Vegas style influence on gambling culture does not stop
at a city's official limits, but extends well beyond earshot of
each casino. Large-scale gambling developments quite evidently
have a much bigger 'impact footprint' than section 129 allows.
In a Blackpool Gazette
Survey on casino proposals for the Lancashire town respondents
were asked: 'what concerns, if any, do you have about resort
casinos coming to Blackpool?' 61.2% of respondents highlighted
crime and 51.5% of respondents highlighted gambling addiction.
"Nobody locally or
nationally appears to have looked at the social costs," argued
Steven Bate, spokesman for the Blackpool Coalition against Gambling
Expansion. "For example, evidence from Australia shows that
two jobs are lost in other businesses for every one created in
casinos." The economic case must always be evaluated and
set alongside the anticipated social cost in an independent and
professionally produced multi-dimensional study plan before decisions
to proceed are taken.
- RESEARCH
A study in Connecticut
revealed that people with incomes below $5,000 spend 14 times
as much on gambling as those with incomes over $25,000. In Maryland
it is 21 times higher. There are no reliable UK statistics on
the cost to society of 'problem gamblers' (British Coalition against
Gambling Expansion).
We recommend that the Government
commission regular substantive research into the prevalence of
problem gambling before and after publishing its proposed Bill.
This should be carried out by the DCMS at regular bi-annual intervals
so that the impact and outworking of the legislation on problem
gambling and the social fabric can be monitored, and where appropriate
corrective action taken.
In light of local concerns,
questions over the true catchment area caught by large scale gambling
developments and the dearth of serious up to date research in
the UK we recommend the institution of baseline research now to
establish crucial foundational statistics on gambling addiction
and associated social costs.
These can then be used
as a benchmark to calibrate ongoing research into the social consequences
of gambling deregulation. There is now a valuable and unrepeatable
opportunity to effectively assess both the claimed long-term economic
regeneration potential of gambling deregulation and the social
consequences of the proposals.
- PLANNING AND SOCIAL
CONCERN
Planners are currently
required by statute to consult certain bodies e.g., the Highways
Agency, Environment Agency, and conservation bodies on the impact
of any development proposal. These we believe are set out in statutory
instruments accompanying the relevant Planning Acts.
We recommend the formal
inclusion of social agencies such as social and probation services,
primary care trusts, hospitals and addiction treatment agencies
and community workers as well as police forces in the list of
'statutory consultees' necessarily involved with any local gambling
planning application. In this connection we recommend the automatic
and statutory commissioning of professional, transparently independent,
multi-dimensional reports into all the implications of such planning
applications which evaluate on an equal basis the economic, infrastructure,
and social implications of proposed gambling developments. It
needs to be continually borne in mind that evidence from the USA
suggests that for every £1 of revenue generated by deregulation,
there can be £3 of associated social costs.
Such professionally thorough
approaches to planning applications should not be difficult to
enact without creating superfluous new bodies or levels of bureaucracy.
This would, however, entail
a significant widening of the definition of planning, usually
strictly limited to 'land use' and 'spatial planning', to allow
for social concern aspects, and would lend teeth to the Government's
declared concern for the social consequences of revolution in
the gambling industry.
- CRIME
We welcome as a Government
licensing objective "preventing gambling from becoming a
source of crime or disorder." There is an evident need to
introduce an effective system for the serious regular investigation
of criminal activity and potential. The Government clearly recognises
the huge potential for drugs and terrorist money laundering that
an expansion of the gambling industry on such a massive scale
will bring. Regular and effective on the spot, unannounced tax
and cash handling inspection powers must be a feature of any new
legislation. The gambling industry is notorious for its evasion
of tax and manipulation of cash and the Government must ensure
that its tax regime is effective especially given the potential
adverse costs versus revenue experience in the USA (see 5 above).
- DEBT
The Evangelical Alliance
is especially concerned with the issue of debt. Debt is a massively
increasing problem in our culture and society, especially at the
present time, and we are worried that the Government is proposing
legislation that will hugely increase the prospects of people
finding themselves hopelessly in debt. Inevitably, experience
shows that it is the poor who are affected disproportionately.
In addition, in this connection
we would emphasise the dangers of using credit cards for gambling,
especially with regard to internet gambling. As the Alliance stated
in its July 2000 submission to the gambling review consultation,
'one should not be able to gamble on a credit card, only through
automated credit transfer (completed debit card) transactions,
the underlying principle involved being that if money is to be
gambled it should be money possessed rather than borrowed.'
In the United States of
America many states have restrictions on credit card gambling.
Many US credit card companies refuse debits from online gambling
websites, and we recommend that the wisdom of this principle be
acknowledged appropriately within the Bill itself.
- INTERNET
We recommend that the strongest
possible controls and monitoring systems are put in place to encourage
best practice in respect of on-line gambling. The National Lottery
Website, whilst by no means perfect, may nevertheless be commended
for its player protection measures. Accordingly, we recommend
a British Gaming Portal with a clear 'kite mark' style approval
system with an appropriate system of health warnings and help
lines. The approach taken by the Government with the sale of marketing
cigarettes should be adopted as a model.
- NATURE OF THE GAMBLING
INDUSTRY
Research from other nations
that have relaxed their gambling laws seems to suggest that a
liberalisation in the gambling laws would favour large casino
developments over racing and the national lottery. Naturally there
is a huge support industry in this country for horse racing with
many livelihoods at stake. There is also a very real issue regarding
the revenue sustainability of the National Lottery's good causes
funding.
Councillor Steven Bate
suggests that in Australia the increase of gambling on slot machines
has caused a decline in gambling in horse racing.
A 2003 draft report by
the State of Maine's casino task force has concluded that a casino
in Maine would hurt the State's harness racing industry and shrink
lottery revenue (Blethen Maine Newspapers Inc.)
While the Alliance is not
advocating one form of gambling over another it would seem wise
from an economic and employment point of view to assess the potential
impact on other established forms of the gaming industry.
- CHILDREN AND GAMBLING
In the U.S.A. compulsive
gambling affects as many as 3-5% of adults and 5-11% of teenagers.
Children are especially
vulnerable to gambling. It seems to matter not whether a fruit
machine is a category D or a category A machine - the addictive
nature of the game-play is identical.
We would also draw attention
to the potentially confusing situation with regard to age restrictions
on gambling. We recommend that the minimum age to play the lottery
should be increased to 18 to match the current age for adult gambling
establishments (this would especially make sense if the proposed
Gambling Commission were to take over regulation of the National
Lottery.)
We welcome the Government's
commitment in the Draft Bill to ensuring that licensing objectives
include protection of "children and other vulnerable persons
from being harmed or exploited by gambling." Special measures
need to be apparent and clearly enforceable to protect children
and other vulnerable people from the potentially damaging consequences
of gambling. Codes of practice and guidelines by themselves are
insufficient.
It is apparent that any
adult susceptible to gambling addiction is a potentially vulnerable
individual, especially if alcohol is to be made readily available
within gaming establishments. It is manifestly irresponsible to
encourage people to gamble when their ability to assess risk is
impaired by alcohol, drugs or other substances. The Alliance therefore
firmly opposes the proposed relaxation of alcohol rules and urges
the complete ban on the sale of alcohol in gaming establishments.
It also strongly recommends retention of the 24-hour membership
rule for playing in casinos to avoid the dangers of people walking
in off the street to gamble in highly vulnerable states. Where
instant access systems exist, those wishing to play should have
to provide details of their identity, contact and financial details,
which would need to be credit checked beforehand. This would allow
for a 'cooling off' period, and would facilitate the 'self banning'
of problem gamblers, as well as weeding out those who may be unfit
to play due to impairment of faculties.
We recommend that at the
very least the gaming sections of any proposed entertainment developments
that include gambling facilities be clearly demarcated from the
family areas of such establishments.
We propose that a separate
reception and membership application area with properly trained
staff should more easily enforce age restrictions. It makes sense
to defend the interests of individuals by insisting on safeguards
that may protect individuals from actions that they would later
have preferred the opportunity to avoid.
With regard to internet gambling as well as gaming
establishments themselves, it is crucial for operators to employ
a statutory system of 'health warnings' together with reminders
about risk and contact details for help agencies. Such a system
should function continuously with play.
- THE COMMITTEE
We acknowledge the apparent
expertise of the Committee members as the list of members' interests
shows a wide experience of the gambling industry. However we are
concerned that there may be a dearth of experience on the Committee
relating to the social consequences of gambling as opposed to
widespread experience and vested interest in the running of betting
enterprises. We would hope that this apparent deficiency will
be appropriately rectified to ensure the Committee's public credibility.
- CONCLUSION
In our response to the
gambling bill we wish the Committee to look again closely at the
potential losers in the revolutionary process of massively expanding
the gaming industry. We must not forget the enormous social costs
that gambling inevitably creates. We accept the Government is
seeking long term solutions to regeneration and the generation
of additional tax revenue. But the regeneration must be of the
right type. The liberalisation of the gambling law must not be
seen as an expedient 'magic bullet' for these issues.
We would be available to
give oral evidence to the committee should they request it.
Gareth Wallace
Parliamentary Officer
Evangelical Alliance
- at the heart
of a movement for change - www.eauk.org
DDI: 020 7207 2129
Fax: 020 7207 2150
Email: g.wallace@eauk.org
| 
