THE BRITISH ASSOCIATION OF
LEISURE PARKS, PIERS & ATTRACTIONS LTD
RESPONSE TO THE PUBLICATION
OF THE DRAFT GAMBLING BILL
8th DECEMBER2003
INTRODUCTION
The Association, established in 1936,
represents the interests of 118 theme & amusement parks, &
piers, accounting for almost 100% of that sector of the Attractions
Industry. Our Membership consists of privately and family owned
and operated facilities, many of which have been passed down over
several generations.
They provide amusement and entertainment
for the family market, principally in the socio economic groups
of Cl, C2 & D. These groups make up a significant proportion
of the British families who continue to holiday, enjoy short breaks,
and days out in the U.K.
This point being particularly relevant
in relation to some of the new restrictions proposed in the Draft
Gambling Bill.
DRAFT
GAMBLING BILL
We have found the Draft to be lacking
in detail in a number of important clauses. Following the publication
of the Policy Instructions earlier in the year, we had anticipated
the Draft Bill would contain specific proposals reflecting that
Document and the submissions made in response.
In consideration of the above, and in
compliance with the request for brevity in response, we have referred
primarily to the points referred to in Clause 193: Gaming machines:
categories A to D.
Based on our understanding that this
clause is likely to contain the detail to which the Policy Instructions
referred, we make the following comments.
In addressing the issue of maximum
stakes payable, the Policy
Instructions referred to a proposed freeze on lOp stake and £5
prize for Category D machines. Should this be included in the
Bill it will not allow businesses to recover any increased cost
which may result from changes in taxation, minimum wage, increases
in utility charges and other expenditure beyond the control of
the operator. We propose that the stake and prize remain a matter
for the Triennial Review currently in operation and which will
we hope be retained.
Value and nature of the prize delivered
as a result of use of a Category D machine. The
Policy Instructions proposes that the current maximum stake of
30p be reduced to 1 Op and non-monetary prizes such as
cuddly toys be restricted in value to
£5, a reduction from the current level of £8, the exception
being cranes (grabbers) which will retain the 30p stake but still
a restricted prize value of £5. These machines are considered
a major part of the entertainment on offer from coastal locations
in particular.
Should these proposals be included in
the Bill, machines offering non-monetary prizes will cease to
be financially viable and result in the removal from the offer
available to families who find these machines not only enjoyable
to play but an economic opportunity to obtain quality gifts for
their children as a souvenir of their visit.
We propose retention of the current
level of 30p stake and £8 maximum non-monetary prize value.
Types of premises. Again
referring to the Policy Instructions, it is proposed that our
Members who currently operate areas restricted to over 18's, known
as designated areas, will not have access to the Category B machines
in other separately designated areas i.e premises within premises.
The proposal will only allow these machines
in premises to which children do not have access.
We believe criteria for premises within
premises, not accessible from Family Amusement Centres, could
be agreed to allow Category B machines to be operated by our Members.
This would allow locations such as theme parks and piers the option
of operating these machines and allow our Members to compete with
the likely increase in this type of machine in Adult Gaming Centres
and the Fixed Odds Betting Terminals being operated in Licensed
Betting Offices.
Clause 16 Codes of Practice
Given the existence of voluntary codes
of practice within the Industry, we assume these will form the
Code proposed by the Commission and will be produced in consultation
with the Industry.
Protection of Children
We would refer to the suggestion that
the Secretary of State reserves the right to introduce primary
legislation to restrict Category D machines for children under
16.
We propose that such legislation could
only be introduced following Government sponsored research conducted
using a brief agreed with the Industry Associations and in circumstances
which have provided clear evidence that such research is necessary.
We maintain that use of Category D machines
by children not only allows the whole family to participate in
harmless and enjoyable entertainment; it provides an opportunity
to encourage responsible attitudes towards the use of machines.
Grandfather Rights
In conclusion, we seek assurance that
the protection of Grandfather rights will be respected in relation
to the ongoing and future renewal of licenses and permits. The
existence of such rights will require clear explanation to ensure
that those charged with the future responsibility on these matters
are clear in the protection such rights confer on existing businesses.
BALPPA Submission 8th December 2003
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