THE GAMBLING BILL
BGRB RESPONSE TO THE JOINT
SCRUTINY COMMITTEE
1. Introduction
1.1 The British Greyhound Racing
Board (BGRB) welcomes the opportunity to give written evidence
to the Joint Scrutiny Committee for the Gambling Bill.
1.2 The BGRB is the representative
body for the sport and industry of greyhound racing in the UK,
which is operated under the Rules of Racing of the National Greyhound
Racing Club. The BGRB Board of Directors comprises elected representatives
from racecourse operators, the National Greyhound Racing Club,
greyhound owners, greyhound breeders and greyhound trainers.
1.3 The BGRB has represented
the greyhound racing industry throughout the process of Gambling
Review, commencing with evidence given to the Committee chaired
by Sir Alan Budd.
2. Structure of Law and Regulation
2.1 The BGRB welcomes a replacement
for the Gaming Act 1968 and recognises that Gambling has become
a mainstream leisure activity in the UK and as such needs to be
regulated both comprehensively and progressively.
2.2 The BGRB is concerned that
the proposals as drafted, whilst adequately setting out the Government's
primary objectives for new legislation, suggest that much of the
working detail will be dependant on secondary legislation and
self regulation. Much of the effect of the proposed legislation
will be dependant on the detail of the decisions of the Minister
responsible at the time, the Gambling Commission and local authorities.
The BGRB considers that more of the detailed proposals and guide
lines should be developed within the timetable of the Gambling
Bill so as to allow a greater understanding of the consequences
of implementation and to provide a forum for public consultation.
3. The Gambling Commission
3.1 The BGRB supports the creation
of the Gambling Commission.
3.2 The BGRB believes that the
Gambling Commission should be transparent in its actions
3.3 The BGRB believes that the
Gambling Commission should as far as possible be operational prior
to the completion of the proposed legislation process so that
the Codes of Practice and guidance for the industry and local
authorities can be published for consultation whilst the Scrutiny
Committee is considering the draft Gambling Bill.
3.4 The BGRB is concerned as
to the cost to the industry of compliance with new regulation
and licensing procedures. It wishes to note that greyhound racing
does not have parity of funding with the horse racing industry
and consequently may struggle to bear these costs if greyhound
racing is regulated in the same manner as horse racing.
4. Local Authority Powers
4.1 The BGRB considers it essential
that clear guidelines are published for local authorities and
that a clear appeals procedure is set out in respect of premises
licensing.
4.2 The BGRB considers it important
that local authorities are required to publish their detailed
strategy in respect of premises licensing and their implementation
of law and regulation so as to allow local representation and
debate.
5. The Town Planning Process
5.1 The BGRB believes it is important
that clear guidelines are set within planning legislation so as
to ensure that the "Demand Criteria" for all forms of
gambling will be abolished and cannot be re-introduced via the
premises town planning process.
6. Social Responsibility
6.1 The BGRB fully supports the
proposed licensing objective (1)(c), and Government's commitment
to the protection of the young and vulnerable.
6.2 The BGRB believes that the
greyhound racing industry has promoted and will continue to promote
greyhound racing as an exciting live sporting spectacle and as
a safe, friendly and socially acceptable opportunity to gamble
as part of an complete leisure experience. In this regard we consider
greyhound racing to be a good example to others of how gambling
can be brought within the mainstream leisure market without unwanted
social side-effects, including widespread problem gambling.
6.3 The BGRB believes accordingly
that licensed gambling operators can compete with other leisure
operators in providing a product suitable for individual, group
and family entertainment, without putting the young and vulnerable
at risk. The BGRB will fully support any measures proposed by
the Gambling Commission to ensure track-based gambling opportunities
are promoted sensibly and responsibly.
7. Definition of a Racecourse
7.1 The BGRB considers that a
"greyhound" or "dog" racecourse should be
defined within the Gambling Bill.
7.2 Such a definition will remove
the ambiguity in the existing definition of a "track"
and should provide for a specific set of rules and regulations
whilst ensuring that new entrants are not able to build and operate
a racecourse without a commitment to the promotion of live racing.
7.3 The BGRB believes it is important that regulations
on the operation of greyhound racing are provided within the authority
of the Commission. The BGRB considers that the cost of licensing
and administration by the Commission can be greatly reduced by
monitored self-regulation by the BGRB and the National Greyhound
Racing Club.
8. Provision of Betting Services
by Racecourse Operators
8.1 The BGRB supports the proposals
that racecourse operators should, subject to holding the required
licenses, be able to operate betting services at a racecourse
which they control or operate, as this will provide a facility
to attract and retain their customers.
8.2 In line with licensing objective
(1)(b), the BGRB supports the proposals that racecourse operators
should not be permitted to take bets, other than pool bets, on
greyhound races or any other live event which they organise and
manage, in order to protect integrity.
8.3 The BGRB suggests that Clause
144 (2)(a) should not refer to days on which "dog racing"
takes place, but days on which "live racing" takes place
to avoid confusion for tracks which also stage car or motorbike
racing over whether children are allowed in areas which would
offer totalisator betting on a dog racing night.
9. Provision of Gaming Machines
at Racecourses
9.1 The BGRB considers that the
number of Category B machines permitted at a Racecourse should
not be limited to 4 (within defined areas and having Adult only
admission) but, where appropriate facilities have been provided,
the number of Category B machines permitted should be linked to
the licensed capacity of the racecourse. This will ensure that
racecourses are able to provide adequate access to such facilities
to meet the demands of their customers.
9.2 Similarly the BGRB considers
that, subject to appropriate facilities being provided restricting
the use by children, racecourses should be permitted to provide
an unlimited number of Category C and D machines, to ensure that
they are able to provide adequate facility for their customers.
10. Payments by On-Course
Bookmakers
10.1 The BGRB believes that the maintenance
of a fee of 5 times admission price for licensed bookmakers to
use a betting pitch should be abolished. This form of protection
of financial arrangement is not appropriate for Greyhound Racing
and should be replaced with standard commercial negotiations.
11. Pool Betting
11.1 The BGRB welcomes the proposals
to extend the accessibility of Pool Betting but considers that
regulations should provide for the operator of the racing or sporting
event to hold the exclusive license for Pool Betting on that event.
The BGRB argues this on the following grounds:
a) That the existence of only
one Pool and only one dividend is in the interest of the greyhound
race betting public
b) That allowing racecourse operators
exclusive licences for greyhound race Pool Betting is in the best
long-term financial interest of the greyhound racing industry
c) That the introduction of new
Pools and the consequent variety of declared dividends would damage
the integrity and credibility of greyhound race Pool Betting
d) That exclusive Pool Betting
licensing is already the case in most other countries, including
USA, Australia, France, Denmark, Sweden and Germany. It has also
been recognised by the UK Government in its proposals for Pool
Betting on Horse Racing.
12. Deregulation of Casinos
12.1 The BGRB supports the proposals
for a minimum size for casinos in order to ensure that small casinos
are considered to be 'destination locations' which therefore require
a 'decision' by the individual to attend.
12.2 However, the BGRB considers
that guidelines to local authorities should permit the development
of smaller casinos within racecourse grounds, where appropriate,
and give priority to such developments on the basis that racecourses
already provide an established and trusted destination for racing,
betting and gaming facilities.
12.3 The BGRB is concerned with the
possible proliferation of large casinos. It believes that large
casinos should only be considered as part of a major regional
tourist development initiative approved and supported by the appropriate
regional authority and tourist board.
12.4 The BGRB recommends that
the Scrutiny Committee gives careful consideration to the potential
effect of large casinos on the established local gambling and
leisure landscape.
13. Betting in Casinos
13.1 The BGRB is greatly concerned
by and vehemently opposed to the proposal to permit betting in
casinos. The provision of such facilities in a de-regulated casino
environment will provide unfair competition to racecourses whose
key selling point is being able to offer betting on live events
in a social and recreational environment.
14. Betting Exchanges
14.1 The BGRB believes that the
Gambling Commission should regulate betting exchanges. Whilst
it acknowledges the work of some exchange operators to monitor
betting activity and report unusual betting patterns to the relevant
authorities, the BGRB believes that the Commission should issue
a specific Operator Licence for betting exchanges which requires
that appropriate integrity measures are compulsory for all operators.
14.2 The BGRB understands the
view of exchange operators that the majority of their users are
'recreational' but is concerned that the pattern of bets being
struck through exchanges suggests otherwise. Accordingly, the
Board believes that users of exchanges over and above an agreed
maximum 'recreational threshold' should require a licence to accept
bets, and should pay Gross Profits Tax and Levy at the appropriate
rates.
14.3 The BGRB notes with concern
the apparent negative impact that large-scale betting exchange
use has made on horse racing's Levy yield. Acknowledging that
betting exchanges are not bookmakers, the BGRB believes that all
exchange users should contribute to the sport on which they are
betting, as well as the exchange itself, through a commission
payable on betting profit made.
15. Spread Betting
15.1 The BGRB believes that spread
betting on sports events should be regulated by the Gambling Commission,
as its product provides direct competition to other betting operators
who the Commission will license under the proposals contained
in the Bill.
16. FOBT's
16.1 The BGRB seeks clarification
of the proposals for the regulation of FOBTs. It recommends that
the categorisation of FOBTs should be as Category B machines and
as a consequence such machines should be available to racecourses
and adult gaming centres.
17. Betting on Live Sport
17.1 The BGRB is concerned that the
draft Gambling Bill has not recognised a need to define the events
on which betting can and should be permitted.
17.2 The BGRB considers that such
a definition is appropriate in order to:
a) Maintain the clear definition
between betting, pool betting, spread betting and lotteries,
b) Maintain integrity of live
sport,
c) Maintain the image of live
sport, and
d) Protect the public.
18. Limits
to Numbers Betting Opportunities
18.1 The BGRB believes that in
line with new FOBT regulatory measures, limits should be placed
on the frequency of lottery draws on which betting is available
and on other forms of random number generated betting 'events'.
19. Further Evidence
19.1 The BGRB would welcome the
opportunity to present oral evidence to the Joint Scrutiny Committee
in due course.
The British Greyhound Racing
Board, 32 Old Burlington Street, London, W1S 3AT
Tel: 020 7292 9900
Fax: 020 7292 9909
www.thedogs.co.uk
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