Joint Committee on Draft Gambling Bill Memoranda


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
  1. INTRODUCTION.

  1. SOCIAL RESPONSIBILITY

A major consequence of deregulation has to be serious acceptance of increased levels of social responsibility by the gambling industry.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. CONCLUSION








RESPONSE

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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).

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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


 
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