27. Memorandum from the Union
of Shop Distributive and Allied Workers (USDAW), Coalition Against
Gambling Expansion and Seasonal Traders Association (GMB 13)
We represent a broad range of views on the proposed
expansion of gambling in the UK. We have come together to focus
on the social and economic effects of slot machines in the proposed
additional casinos. Concerns about the displacement of takings,
profits and hence jobs [from business near proposed casinos] are
our first focus. This evidence and our campaign have become national.
Therefore there is no reference to the town of our origination.
The big issue that concerns us secondly, is the lack of public
debate on a presumption. The public have not been asked if they
consider high stake, jackpot slot machines to be "normal
entertainment". Also over four years our concern has grown
that Government is attempting to ignore evidence that 30 per cent
to 55 per cent of similar casino slot machine revenue [in USA]
comes from pathological gamblers. The evidence following is also
part of our campaign to encourage an ethical aspect to the long
avoided debate.
1. In the same way that DCMS responded to
recommendations 79,80,81,83,84 and 85 generally as well as on
specific points, we shall do similar. Our concerns focus on the
social and economic effects associated with slot machines in casinos.
2. We welcome the statement "its social
consequences reach well beyond the wallet of the individual gambler"
and "The Government acknowledges that a rapid and uncontrolled
increase [casino jackpot slot machines] could present too significant
a risk, in terms of stimulating problem gambling and its social
consequences." We acknowledge and welcome the considerable
change of tone from the Government as compared to the previous
four years.
3. Therefore we cannot understand the suggestion
that the proposed regional casinos will not stimulate gambling
and therefore create a measurable increase in problem gambling.
This aspect of the Bill is the part that we assert is fundamentally
flawed. The proposed regional casinos would not be built, unless
the developers were confident that millions, of extra UK residents
were going to visit them on an occasional or regular basis.
4. We have not the resources to undertake
suitable research. However it would be sensible to expect that
the percentage of UK residents that will visit occasionally UK
casinos, will increase ten fold from the current 3 per cent to
around 30 per cent. Whether or not this ten-fold increase in visitors
to casinos will lead to a ten-fold increase in problem gambling
is a matter that deserves public and parliamentary scrutiny and
debate.
5. If Government is serious regarding policy
being informed by research, on for example measuring the effect
of [category A] jackpot slot machines on stimulating problem gambling,
it should allow trials in a select number of existing casinos.
Likewise on one of the trials it could also allow a casino to
promote and provide unlimited quantities of free drinks, free
meals and free accommodation. This would be "ground breaking"
and a "world first" method of discovering how much that
activity, stimulated demand and later possible problems, as compared
to the potential slot machine jackpots themselves.
6. The Government response to these joint
committee recommendations contain contradictions, and some smoke
and mirrors attempting to avoid the evidence, that overall virtually
no jobs will be created, and no genuine regeneration can be enabled
by the current proposals. Government should openly admit [for
example] similar casinos in France obtain over 90 per cent of
their revenue from slot machines. It is generally accepted that
of all the casino revenue in the USA, 80 per cent of it comes
from slot machines.
7. Public understanding of this part of
the proposed legislation would be improved, with more open acceptance
of key evidence. For example that positive benefits only exceed
negative effects, if more than half of casino revenue comes from
"high rollers" from other regions. Evidence indicates
that only Las Vegas [plus a few select London casinos] achieves
this. The much-prized "high rollers"" do not gamble
on slot machines and few would travel to "regional"
UK casinos in preference to Monte Carlo or Las Vegas.
8. Government should acknowledge that regional,
large and small casinos will obtain almost all their profits,
from the regions or communities they serve, and the profits will
go wherever the owners decide. We disagree with the Government
rejection of all options [tax, licence fees, auction of monopoly
rights etc] that may enable communities to obtain direct revenue.
Those funds are required to treat local problem gamblers, and
mitigate other negative social and economic impacts that those
casinos will cause. Also [if there is any money left] to actually
fund genuine regeneration projects, subsidise sporting, cultural,
and tourist facilities. Without that long-term revenue stream,
we assert that the proposed regional casinos, will not provide
any significant regeneration for the communities they are directed
to.
9. We disagree with the Government proposals
regarding planning approvals for casinos. We suggest a system
is produced similar to that used with regard to very large supermarkets.
New supermarkets take trade from other supermarkets and from town
centre shops. The effect is measurable and conflicting interests
can put their case to planners and the interests of small local
shops are given due weighting by planners.
10. Under the amended proposals new small
casinos will provide betting, so local bookies and other small
casinos should be able to present a case to planners regarding
how this increased competition may affect turnover and jobs. Working
men's and political social clubs should be able to object [and
be taken seriously] if they have an indication that significant
numbers of their regulars will transfer their slot machine spending
from those clubs [often not for profit clubs] to any new proposed
casino.
11. The easy access to and ability of casinos
to advertise, could have more economic impact locally than any
planning issue. After five years of three heavily advertised casinos
in Detroit, problem gambling rates have increased to 11.4 per
cent of the local population. Local hotels, shops and restaurants
report no increase in trade at all. All the measurable benefits
result from locals gambling in Detroit rather than over the border
in Canada. Half the casino tax goes to the Michigan State Education
budget, the other half to the city council general budget. There
are now an estimated 330,000 problem gamblers in Michigan State,
but 8,200 people have obtained jobs in the three casinos.
12. Under the amended proposals large casinos
will also offer betting and bingo. Therefore in addition bingo
clubs [within a certain distance], should have their economic
interests taken seriously in considering large casino licence
and planning applications. With a level playing field [equal resources]
evidence could possibly indicate that a particular large casino
would displace or transfer almost all its revenue and therefore
jobs from other existing gambling venues.
13. We recommend that financial resources
be made available to community groups seeking to make their case
locally and regionally regarding each new casino licence and planning
application. Without this there is no doubt big business and big
government interests will overwhelm community interests.
14. We are pleased that the Government has
effectively rejected the term "resort casino" in favour
of the more realistic term of "regional casino" for
very large casinos. However we disagree with the presumption that
the more non-gambling facilities they offer in connected rooms
the better for the local community.
15. We have seen estimates that "the
UK market" will take 15 to 30 of these regional casinos.
It is generally accepted that US investors want them to be in
city centres, in many cases attached to sports or exhibition facilities
[which they will subsidise]. We assert that the more non-gambling
facilities they offer, the more these complexes will be in competition
with the existing city centre leisure businesses.
16. If the regional casinos are allowed
to offer non-gambling products and facilities as loss leaders
or free, the displacement of turnover [takings] and jobs will
be dramatic. Planning permissions and licensing conditions must
be arranged to take seriously, local and regional consultations
and representations on these displacement effects.
17. Even if the above may not be offered
free or as loss leaders and inducements, the effect will still
be measurable, and due weight must be given to trade representations
on any such proposals. We urge the Joint Committee to study the
largest casino in the world Foxwoods. We understand it attracts
around 40,000 gamblers each day. No businesses have set up near
to it offering non-gambling facilities. They would not, as food
and drinks etc are provided at loss leader prices in the casino
complex. There are no spin off advantages to the local community.
18. We agree with the Government statement
that; "uninterrupted gambling might increase the risk of
excessive or uncontrolled play". We recommend that the most
effective way to avoid the risk is to avoid the opportunity. To
have eating, drinking and other leisure activities in rooms next
door is preferable to them being in the same room. However is
this in addition to or in place of? This requires clarification,
to not allow waiter/waitress's to serve food and drink to slot
machine players would be a far better regulation, which we recommend.
19. We also urge Government to actually
ban eating, smoking and drinking while at the slot machines. This
would be even more effective at "avoiding excessive or uncontrolled
play". Please remember the evidence about how common pools
of urine are, next to slot machines in some casinos.
20. With an application for a regional casino
somewhere with few existing dining and drinking establishments
nearby [say Barrow], we could see the logic of facilities being
included close by as proposed. However we assert that the only
way that regional casinos in city centres and existing busy seaside
towns could obtain genuine spin off regeneration advantages, would
be if gamblers were obliged to leave the premises to dine, drink,
obtain accommodation and shop in existing business's nearby. For
four years we have campaigned Government to consult and debate
on these issues, we are still waiting for the debate to start.
21. The Government should accept that the
concept of "resort casinos" is a clever public relations
and marketing ploy by the new breed of casino promoters and developers.
The public relations campaign promotes a "normalisation"
of hard gambling forms, it will bring in a lot of new customers
and later a lot of new problem gamblers will be created. The Government
should ask itself why it wants to induce those with children into
hard forms of gambling or culturally normalise casinos for children.
The worlds only full time campaigner on these issues Tom Grey,
has described the publicity for the lottery as "opening the
door to hardcore forms of gambling" and these Government
proposals as "kicking the door off the hinges."
22. We disagree with the Government proposal
that the detailed specification of non-gambling facilities attached
to regional casino gambling facilities should be left to Gambling
Commission guidance to licensing authorities. The details should
be debated and agreed by parliament, and should be in the legislation
for public inspection and consultation now. Any public or local
political support that exists for regional casinos, is based totally
on the non-gambling facilities that have been hinted at. There
is virtually no public or local political support for the slot
machines themselves. All the stakeholders need to know the details,
regarding exactly what can be demanded from regional casino licence
applicants. This is essential now, as the Government have refused
local government any cash share of the slot machine profits.
23. The Government appears to condone and
encourage the confusion between casino licensing requirements
and casino planning regulations. It is what happens in a casino
that has an economic displacement effect and may increase problem
gambling, rather than the building itself. Evidence previously
to the joint committee indicates local and regional planning professionals,
are completely unable to speak with authority, on the effects
of regional casinos that concern us.
24. A senior planning officer told the author,
that the only issue a council may influence with regard to casinos,
was the illuminated sign outside [and that was a matter delegated
to officers, so no elected member involvement]. We recommend that
detailed licensing requirements be included in the Bill, be debated
and agreed by parliament and wide public and leisure trade consultations
be instituted ASAP.
25. Local and regional planning officers
are only qualified to deal with matters of traffic flow, loss
of light, parking and appearance of buildings. There is an urgent
need for an independent body of experts, attached perhaps to the
Gambling Commission, that can assess the economic effect and social
cost of each casino licence application.
26. The Government claims in a positive
tone that their proposals will ensure "vigorous competition
between operators and premises." We suggest this totally
contradicts a number of statements in the forward by the Minister.
In the market economy vigorous competition either stimulates extra
demand, or puts competing service providers out of business, or
some of both. In the interests of open government we suggest the
Government makes public estimates of how many jobs will be displaced
from bookies, bingo halls, pubs, not for profit social clubs,
amusement arcades, cafes, hotels, restaurants etc. by this "vigorous
competition."
27. We welcome the Government acceptance
that there is significant risk of increased problem gambling associated
with Category A slot machines. However we question the Government
suggestion that confining them to regional casinos is a wise response
to this significant risk. We agree that "minimising repetitive
casual use" of them is essential. However the proposal to
site them in the heart of socially and economically deprived community's
conflicts with this laudable aim.
28. There is a great deal of evidence from
Australia, Canada and various US States that the one-hour travel
distance is the key aspect. From recent UK media coverage of various
city centre casino proposals, it appears that a very large percentage
of the UK population, will be within a one-hour travel distance
of a regional or large casino. We therefore suggest that Government
needs to rethink and redraft this part of the legislation.
29. Specifically we urge Government to not
allow any venue containing Category A slot machines within three
miles of any urban area with a high percentage of low income,
unemployed or socially deprived residents. The social costs of
increased problem gambling, if they are within walking distance,
will exceed the benefit to the community, of a few of them obtaining
employment in those venues.
30. The Gaming Board/Gambling Commission/
Regional planning bodies have little or no knowledge of the economic
and potentially habit-forming effects of various marketing practices
and inducements, which are common in resorts such as Atlantic
City. With two out of three hotel rooms offered free to regular
gamblers, similar activity in post deregulation UK would cause
significant impacts. Government should detail how it proposes
to take these impacts in to consideration with each new casino
licence application.
31. The Government should reconsider its
refusal to allow local communities any method of obtaining a direct
share of the money lost in casino slot machine gambling. Virtually
all of the hundreds of similar new slot machine venues allowed
in Australia, Canada or US States in the past 15 years, obtained
local or regional public approval, because they pay 10 per cent
to 50 per cent of their profits to fund local or regional public
services.
32. We disagree with the Government proposal
to omit from the bill, details regarding which inducements may
or may not be provided by casinos. The Chairman of the Gaming
Board told the author that he had no knowledge about the type
or quantity of inducements that are provided to regular gamblers
in Atlantic City.
33. If regional planners are going to decide
the details of what type and size of casinos are to be "directed"
to particular towns or city centres. The Bill must explain what
marketing and inducements are permitted. There is evidence that
the inducements can have more impact on the size and number of
casinos that are profitable in a city, than any planning conditions.
34. We assert that the effective scrutiny
of this part of the Bill is made virtually impossible as the joint
committee and those offering evidence do not know what tax rate
the casinos will have to pay. We do know that each slot machine
could raise up to £100,000 per year. Without knowing how
much tax is payable, how can anyone know what remains for dramatic
buildings, subsidising entertainments, inducements, attached exhibition
and conference facilities, sporting facilities and other leisure
facilities. It is those that people want to know about in detail,
in advance, before the Bill goes before Parliament. Government
must announce now what the tax rate [gambling duty etc] will be
on all the new and existing types of casinos, when the Bill is
passed.
35. We disagree with the assumption suggested
in the relevant amendments to the Draft Bill, that the proposed
casinos will provide entertainment and a "quality leisure
experience" for young tourists. Experience from overseas
indicates the reality will be [for most hours of the week] over
70per cent of clients will be female pensioners [from the region]
who rarely interact with each other, sitting at slot machines
until the free snacks, free drinks or their cash runs out. We
assert they are not tourists and that is not entertainment.
July 2004
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