Conclusions and recommendations
1. While
further work is needed to resolve the conflicting objectives of
the Department for Culture, Media and Sport and the Office of
the Deputy Prime Minister we do not believe that this should delay
the introduction of the Bill to Parliament. We maintain the view
expressed in our original report that the legislation is necessary
and urgent and urge the Department of Culture, Media and Sport
and the Office of the Deputy Prime Minister to work together to
resolve the outstanding issues at the earliest opportunity. (Paragraph
5)
2. We expect regional
casinos to be large scale entertainment complexes offering
gambling alongside a wide range of non-gambling facilities. This
concept is not adequately captured by the current classification.
We therefore recommend that the Department considers an alternative
name for this category of casino, which more accurately conveys
the nature of such developments. The Committee is minded
to suggest that the term leisure destination casino more
suitably describes the Government's proposals and reflects
the Committee's thinking. (Paragraph 15)
3. We recommend that
the minimum total customer area for regional/leisure destination
casinos is increased to 7,500m². This will consist of
a minimum table gaming area of 1,000m², a minimum additional
gambling area of 2,500m² and a minimum non-gambling area
of 4,000m². We would expect the non-gambling areas to include
leisure and entertainment facilities, consistent with guidance
set by the Gambling Commission. We believe that the minimum gambling
area is adequate to accommodate 1,250 gaming machines; a gambling
area greater than the proposed minimum does not justify increasing
the cap on the number of gaming machines. We therefore do not
believe it is necessary to increase the maximum number of Category
A machines a regional/leisure destination casino is
permitted. (Paragraph 24)
4. We believe that
increasing the minimum total size for a regional/leisure destination
casino will increase the size of the investment required to
create such a facility, which in turn may limit the likely number
of regional/leisure destination casinos to somewhere around
20 to 25. We believe that it is appropriate to have fewer regional/leisure
destination casinos than has been suggested by some of the
evidence we have received. (Paragraph 25)
5. We do not feel
that the proposed minimum non-gambling area is large enough to
accommodate suitable leisure, sports, arts and cultural facilities.
As we discuss in more detail above, we recommend that the non-gambling
area for regional/leisure destination casinos is increased
to a minimum of 4,000m² in order to accommodate the entertainment
and cultural facilities necessary to provide an overall leisure
experience. (Paragraph 28)
6. We support the
Government's proposals to allow children into the non-gambling
area of regional/leisure destination casinos, provided
that there are appropriate barriers and a suitable distance between
the gambling and non-gambling areas. To do otherwise would limit
the potential for regional/leisure destination casinos
to develop as all-round facilities, offering entertainment and
leisure facilities to those who do not wish to gamble, including
families, as well as those who do. (Paragraph 33)
7. We do not believe
that children should be permitted into the non-gambling areas
of small and large casinos as these will be too
small to offer the range of facilities available in the non-gambling
area of a regional/leisure destination casino and to ensure
that a suitable distance can be maintained from the gambling
area. (Paragraph 34)
8. We recommend that
the primary responsibility for enforcing the separation of the
gambling and non-gambling area should rest with the Gambling Commission,
in line with the licensing objective to protect children and the
vulnerable. We expect the Commission to work with local authorities
who grant premises licences and to issue guidance setting out
the kinds of non-gambling areas that are suitable for children.
We so recommend. (Paragraph 37)
9. We welcome the
Government's commitment to carry out a national survey of gambling
participation and problem gambling prior to the implementation
of the Bill but recommend that additional research is carried
out into Category A machines and their potential for addiction.
(Paragraph 41)
10. We recommend that
the Department for Culture, Media and Sport, in consultation with
the Gambling Commission and the existing industry, considers an
appropriate entitlement for casinos which were in operation before
the 7th August 2003 (the date on which the original policy statement
on casinos was published) to have a proportion of their gaming
machines as Category A gaming machines. Such discussions should
be informed by the outcome of the Government's revised Regulatory
Impact Assessment and Competition Assessment and the agreed entitlement
should be reviewed after three years, following research on the
impact of Category A machines. (Paragraph 47)
11. Subject to the
outcome of such research we recommend that the question of whether
new small and large casinos should be entitled to
have a proportion of their gaming machines as Category A machines
is also reviewed. We recommend that this review should consider
allowing new small and large casinos to have a proportion
of their gaming machines entitlements as Category A machines if
they build up a good record in respect of social responsibility
over a period of, say, three years. (Paragraph 48)
12. We do not understand
the logic of reducing the minimum number of gaming tables, whilst
maintaining the minimum table gaming area for small and
large casinos. We recommend that the Department for Culture,
Media and Sport consults the industry to consider more appropriate
minimum gaming table requirements, which allow the industry reasonable
flexibility but which also avoid the risk of a proliferation of
new very small casinos. 500m² is thought sufficient to accommodate
20 tables and 1,000m², 40 tables. These were the minimum
number of tables required under the Government's previous proposals.
As a large casino would need only 30 gaming tables to secure
the permitted maximum of 150 gaming machines, it is unlikely that
any large casinos would have as many as 40 tables. (Paragraph
49)
13. The Committee
believes that there are valid competition issues arising from
the significant changes to the Government's original proposals
that must be given due consideration before the debate is concluded.
We therefore recommend that the Department for Culture, Media
and Sport undertakes full revisions of its Regulatory Impact Assessment
and Competition Assessments without delay. (Paragraph 53)
14. Category A machines
remain untested on the UK market. The Government's proposals for
regional/leisure destination casinos to have up to 1,250
Category A machines allow for a major expansion in the number
of gaming machines in the UK. Given the uncertainties about the
possible impact that Category A machines may have on problem gambling
we welcome the Government's cautious approach and do not believe
that an increase in the maximum cap for regional/leisure destination
casinos is justified. We so recommend. (Paragraph 56)
15. We welcome this
provision and recommend that the Gambling Commission, in consultation
with the Department for Culture, Media and Sport and the gambling
industry, develop a schedule of varying stakes and prizes for
Category B machines in different gambling premises. Specifically,
we suggest that there is a strong case for substantially increasing
the maximum stake and prize limits for Category B machines
located in casinos. (Paragraph 64)
16. We recommend that
the maximum number of gaming machines permitted in small and
large casinos should be reviewed by the Gambling Commission
three years after Royal Assent and that appropriate recommendations
should be made to the Secretary of State for Culture, Media and
Sport. (Paragraph 65)
17. We strongly urge
the Government to rethink its policy in this area [planning for
regional/leisure destination casinos] and to pay proper
regard to the evidence given to this Committee about how best
to secure the Department for Culture, Media and Sport's policy
objectives for casino developments which this Committee supports.
(Paragraph 69)
18. While we acknowledge
the Government's reluctance to publish national guidance relating
specifically to regional/leisure destination casinos, we
believe that it could help to ensure a consistent approach between
regional authorities and avoid the need for applications to be
called in for determination by the First Secretary of State. (Paragraph
75)
19. The Committee
is disappointed with the lack of policy coherence in this area
and has grave concerns about locating regional/leisure destination
casinos in areas in close proximity to where people live and
work. While we accept that planning policy is established in line
with the Office of the Deputy Prime Minister's wider objectives,
we believe that the overriding objective of the Government's proposals
in this area should be that of controlling the access to Category
A machines by limiting the number of premises that can have them
and ensuring, so far as possible, that they are not located in
close proximity to residential properties. (Paragraph 84)
20. While we strongly
believe that regional/leisure destination casinos should
be large scale leisure complexes with ancillary entertainment
and cultural facilities we are concerned about the potential for
regional/leisure destination casinos to develop alongside
housing. Given the concerns about the impact "convenient"
and "casual" gambling can have on problem gambling,
we do not believe it is appropriate for regional/leisure destination
casino developments to contain provision for housing. We so
recommend. (Paragraph 85)
21. The Committee
believes there is merit in the suggestion to make all casinos
sui generis. We believe that this is particularly relevant
in respect of regional/leisure destination casinos. Categorising
regional/leisure destination casinos in a separate Use
Class will prevent existing premises within the D2 Use Class,
including other casinos below the minimum size threshold for regional/leisure
destination casinos, from converting to regional/leisure
destination casinos without the need for planning permission.
This means that regional/leisure destination casinos would
not be able to develop without achieving new planning permission
and therefore meeting planning obligations. Having a separate
Use Class for regional/leisure destination casinos will
also help to prevent their proliferation as new developments will
have to comply with the policy set out in the Regional Spatial
Strategy. We therefore recommend that regional/leisure destination
casinos are categorised as sui generis and that the
Government consults on whether a sui generis categorisation
should apply to all casinos. (Paragraph 90)
22. The Committee
is concerned that the lack of clarity surrounding regeneration
benefits could result in potential regeneration benefits being
lost. This is a serious risk which needs to be addressed if regeneration
benefits are going to be secured. We recommend that the Government
reviews its approach to regeneration associated with regional/leisure
destination casinos. (Paragraph 92)
23. We recommend that
Gambling Commission guidance should include advice to local authorities
on identifying appropriate locations for regional/leisure destination
casinos and the importance of ensuring that all planning issues
are properly concluded before premises licences are granted.
(Paragraph 94)
24. The development
of national guidance for Regional Planning Bodies, amongst other
issues, could be addressed by a Working Group consisting of representatives
of the Department for Culture, Media and Sport, the Office of
the Deputy Prime Minister, the Gambling Commission, RPBs and the
industry. We therefore recommend that such a Working Group, is
established at the earliest possibility with the aim of
concluding a planning framework for regional/leisure destination
casinos which reflects the policy objectives of protecting
the vulnerable and securing regeneration benefits. (Paragraph
95)
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