22. Memorandum from Leisure
Parcs Ltd (GMB 5)
OVERVIEW
1. The Government's response strikes a reasonable
balance between commercial opportunity on the one hand and good
public policy on the other.
2. The current proposals go a considerable
way to avoid a proliferation of high payout slots, as well as
to lessen the social and economic impact on city centres and to
aid regionally supported regeneration and tourism projects.
3. In general terms we believe that the
current proposals represent good news for those destinations that
have regeneration aspirations.
Regional Casinos
4. We welcome the identification of a third
new category of casino, that of a "regional" casino.
5. We believe that the definition of a "regional"
casino on the basis of the minimum sizes stated for gambling and
other public areas is appropriate.
6. We agree it is sensible not to specify
in the legislation what ancillary leisure facilities should be
provided (eg restaurants, bars, cafes or cinemas).
7. We agree that Category A slot machines
should be restricted to "regional" casinos. This will
create a clear distinction between "regional" and "large"
casinos and promote commercial interest in those projects that
have a greater capacity to deliver substantial numbers of better
skilled jobs as well as more meaningful and sustainable regeneration.
8. Capping the number of Category B machines
for both `small' and "large" casinos and implementing
the slot to table ratios at the levels proposed by the Government
will further aid the clear distinction between "regional"
and other casinos.
9. We also agree with the ratio of 25 slot
machines for every gaming table but we believe that restricting
the total number of machines to 1,250 will unnecessarily limit
the development potential for ancillary leisure facilities and
thereby limit the total number of jobs a regional casino project
creates.
10. We suggest that the absolute number
of slot machines for a "regional" casino should be a
matter agreed between the licensing authorities and the operator
on the basis of the project's regeneration merit, albeit at a
ratio of 25 machines to every gaming table.
11. We welcome the Government's pragmatic
response to the issue of gaming tables "available for use".
Specifically, we believe the proposal that a casino must have
a minimum number of qualified staff that reflects the number of
gaming tables is sensible.
12. We do not believe that the Government's
proposals offer any impediment to UK businesses that wish to operate
Category A slot machines; the development of "regional"
casinos is not restricted to international inward investment.
Planning
13. In general terms we welcome the Government's
proposal that Regional Planning Bodies will, by way of a Regional
Spatial Strategy, set out planning policies for leisure developments
of regional and sub-regional significance, including regional
casinos, which identify the most suitable locations that would
optimise their contribution to tourism and regeneration.
14. We believe that the proposed use of
planning regulation is an appropriate process by which a region
can determine for itself where best to locate regional casino
development. This should ensure an effective and cohesive approach
to securing economic benefits in the areas of greatest need.
15. However, we are concerned that without
a specific national policy framework to further guide the regional
planning bodies regarding the location of "regional"
casinos there will be conflicts of interest both within and between
regions.
16. Given that the ODPM may, from time to
time, "call in" planning permissions relating to regionally
significant leisure uses such as "regional" casinos,
it would seem reasonable that a national policy was given further
consideration.
17. We continue to urge the Government to
stipulate that "large" as well as "regional"
casino development will require the approval of Regional Planning
Bodies.
18. In the Annex to its response the Government
says "new large casinos will be located in the most appropriate
places in terms of their tourism and regenerative potential"
(Para 28); does this refer to both "large" and "regional"
casinos?
19. We are particularly concerned that the
Government makes no reference to establishing a new use class
order for casinos.
20. Without a new separate use class order
we are concerned that significant numbers of existing D2 use properties
(bingo halls, sports halls, cinemas and the like) will be converted
into "large" and "regional" casinos regardless
of regional planning policies. We believe that many local and
regional authority planners share this concern.
LEISURE PARCS
LIMITED
21. Leisure Parcs Limited is a private company
owned by the family interests of its chairman, Mr Trevor Hemmings,
Electra, a private equity company and HBOS Plc (Halifax Bank of
Scotland).
22. It was formed for the express purpose
of delivering a vision of a rejuvenated Blackpool economically
driven by destination casino hotels, primarily competing for both
day visits and short-break stays within the UK market.
23. The company owns a large number of key
tourism assets in Blackpool, which include Blackpool Tower and
Circus, Louis Tussaud's Waxworks, the Sea Life Centre, the Winter
Gardens Conference Centre, hotels, amusement arcades and the three
piers. The company also owns piers in Eastbourne, Llandudno and
Southsea.
24. Working closely with Blackpool Borough
Council, sub-regional and regional partners, including Lancashire
West Partnership, the North West Development Agency (NWDA) and
the North West Regional Assembly (NWRA), Leisure Parcs' strategy
is to inspire a vision of Blackpool as a vibrant, all year round,
diverse and quality driven resort that will appeal to visitor
and resident alike.
25. At the heart of this vision is the development
of destination casino hotels that will act as a catalyst for massive
regeneration, thousands of jobs and significant investment in
skills, which in turn will deliver wider prosperity and improved
quality of life for local residents and businesses.
June 2004
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