WRITTEN EVIDENCE SUBMITTED TO THE PRE-LEGISLATIVE SCRUTINY COMMITTEE FOR THE GAMBLING BILL
THE POTENTIAL
Blackpool Council with all party support and the support of the
largest part of the Blackpool Community would like to make the
following points in relation to the Draft Bill:
Clearly the time is right to bring gaming into the 21st
Century and address the inconsistencies that exist. In achieving
this objective however there are both opportunities and risks.
This submission will focus on the issue of casinos and big/unlimited
prize machines. We believe the principal risks in deregulation
are: -
· proliferation and inadequate
controls leading to an unacceptable increase in social problems
and problem gaming as well as a potential increase in criminality;
· rapid early development
and potential over provision leading to a product that fails to
deliver the quality and choice that is hoped for and expected
from this new leisure industry;
· the emergence of a pattern
of casino development that undermines both the viability of existing
urban centres and community cohesion;
· a pattern of investment
that misses key opportunities to deliver much needed regeneration
and does not capitalise upon the potential to create new, international
tourism destinations in the UK economy.
To begin with caution would be sensible with tight controls applied.
These could be relaxed in a deliberate and considered manner,
later on, if these fears prove unfounded.
PROPOSALS
Taking the concerns above into consideration casino gaming with
more than a few unlimited prize machines should be encouraged
only as a destination experience and mechanisms and controls established
to limit the proliferation of 'small' casinos. Two possible approaches
are put forward.
- Approach 1
In particular therefore the Council believes that:
· with
the exception of existing casinos new 'small' casinos should have
a minimum size and that the proposed 5,000 sq ft gaming table
area with no more than 3 unlimited prize machines per table is
broadly right. Certainly any more than 3 machines per table should
be resisted.
· Additionally,
a special planning use class for casinos should be established
to ensure appropriate locational controls are in place as well
as the licensing controls through the gaming commission and local
authority licensing mechanisms.
· large
casinos should be differentiated clearly from small casinos and
we would suggest therefore a maximum size for small casinos of
10,000 sq ft of gaming table area. The entry point for large destination
casinos would be a minimum of 15,000 sq ft of gaming table area
with at least 40 gaming tables.
This brings us to the second key objective. Using
opportunities provided from casino liberalisation to:
· generate
additional income to the UK contributing to the national economy
by bringing people into the UK for gaming associated leisure and
encourage individuals to remain here rather than go abroad (the
intended expansion of casino gaming by American operators into
Spain and former Eastern European Countries will provide easier
opportunities than have existed before);
· help
regenerate appropriate areas such as resorts and similar communities
identified within Regional Economic Strategies as meeting need
and providing opportunity.
To this end large casinos which could have an
unlimited number of unlimited / big prize machines should:
· be
larger than 15,000 sq ft of gaming table area, constitute a range
of uses (defined in a planning definition?) which form a significant
part of the total area encompassing entertainment, food, retail
and possible hotel uses;
· be
located only in areas where the Regional Economic Strategy (RES)
and the Regional Spatial Strategy (RSS) identifies them as contributing
to the regeneration and economic prosperity of the region and
communities within which they are to be located. There should
be a compulsory referral of all applications for 'large casinos'
to the regional planning body to ensure that the provisions of
the (RES) and (RSS) are upheld. The Secretary of State should
have powers to call in these proposals where they are not in accordance
with the RES and RSS or where possible conflicts between regions
exist.
Because they are intended to be destination experiences
a few places only would be expected to meet this criteria. This
would be the ideal for Blackpool and other areas that could benefit
immensely from large scale destination casinos.
- Approach 2
The Council has recognised that there will be
immense pressure for these 'large scale' casinos. If there is
no other option above the 10,000 square feet plus 120 gaming tables
maximum small casino, the regional planning authority may well
be inundated with referred applications. We would therefore like
to proposes a 3 tier hierarchy with a middle option. This approach
seeks to recognise the high demand that there will be for mid
size casinos. These would also need to show regenerative impact
and be part of regeneration effort identified in the Regional
Spatial Strategy but they would not need to be quite so few in
number as the large scale casinos. These developments would have:
-
· between
10,000 and 15,000 square feet of table gaming floor
· be
permitted to have up to 300 unlimited payout slot machines
· the
potential to aid wider regeneration aims for the immediate area
· to
accord with the Regional Spatial Strategy and Regional Economic
Strategy
We present this as an option not because we are
strongly in favour of it, but because of our concern that the
alternative is to allow a large or unlimited number of unlimited
payout slot machines in developments that are neither small scale
casinos or large scale casinos. This would destroy the potential
of large scale casinos in significant regional and national regeneration
projects.
We would of course be happy to discuss any of
this submission further with the committee if required
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