37. Memorandum from The Bingo
Association (GMB 37)
1. The Bingo Association is the trade association
representing owners and operators of commercial bingo halls licensed
under Part II of the Gaming Act 1968. Our membership ranges from
the largest companies, operating well over 100 clubs each, to
companies operating just one club. Our members' interests cover
the whole of Great Britain.
2. The Government has addressed a number
of important issues in its response, and the industry is pleased
to note that it has taken on board a number of recommendations
made by the Scrutiny Committee that relate to bingo. In relation
to the Committee's further deliberations, the Association has
the following comments to make.
3. The first point that we must make clear
is why The Bingo Association is interested on behalf of its members
in relation to the two areas that the Scrutiny Committee have
been asked to assess. The basic reason is that the development
of both regional and large casinos, which will have the opportunity
to provide bingo, are of course of considerable importance to
many of our members. In the circumstances we feel that we would
like to comment on aspects of the Government's response because
we do not believe that it is abundantly clear as to what will
actually be the procedures to be put in place to deal with the
building of both the regional and new large casinos.
PLANNING ISSUES
4. Although the Government's more detailed
statement on planning matters is welcome, there remain a number
of areas of concern. The planning system itself is clearly still
in a state of transition, making it difficult to obtain a clear
picture of the inter-relationship of new guidance. Whilst there
has been consultation on the new PPS11, it is not yet in place,
and the proposed PPS6 is only "emerging". In particular,
the means by which the various bodies will consult during the
development of regional and local policies is open to question.
It is possible to envisage a situation where neighbouring Regional
Planning Bodies will each determine a preferred location for a
regional casino, with the possibility that three will emerge in
a relatively small area.
5. Additionally, in the annex to the Government's
response it states that new large casinos (which we assume does
mean "large" rather than "regional") will
be located in the most appropriate places etc. It is far from
clear how this can be ensured. If the object of the Government's
response is to limit not only the number of regional casinos but
also large casinos, it seems essential that there is a clearer
indication of how this is to be done. It is surmised that, because
regional casinos are considered important for the regeneration
effect that they can have, the positioning of too many large casinos
within what might be called the catchment area for, say, a Blackpool
regional casino is to be avoided or discouraged. This is why it
becomes essential for those who are intending large scale investment
to know what the rules are to be eg the planning and building
of a regional casino could take a considerable amount of time
and certainly will involve a very large investment. Without any
check on the number of large casinos within a reasonable distance
one would have thought it would be difficult to persuade companies
to invest enormous amounts of money which might not show the return
that they hoped for.
6. There are also a number of potential
complications in the run-up to any new legislation. For bingo
clubs, the new proposals mean that many who had the option of
converting to a casino licence will now no longer be able to do
so, since they were most likely to fall in to the small casino
category. However, those which are located within existing permitted
areas may be able to do so ahead of new legislation, in order
to secure grandfather rights, whilst those outside permitted areas
would not. This is clearly not desirable. It is also difficult
to see how ongoing applications for large casinos will be reconciled
at a later date with a preferred location for a regional casino.
7. Whilst the Government's statement gives
more detail on policy for casinos, once again it fails to take
account of the likely impact this will have on other sectors.
The size and location of future casinos will be critical to the
survival of many bingo clubs, many of whom have been effectively
prevented from converting where they cannot survive as a stand-alone
bingo entity.
8. Another area of concern is the vagueness
regarding the right of the Office of the First Secretary of State
to call in planning applications. The annex states that the First
Secretary of State is selective about calling in planning applications
and will in general do so only if planning issues of more than
local importance are involved. Clearly a definition of what is
local is needed.
CATEGORIES OF
CASINO PREMISES
9. Regarding the proposals for the minimum
sizes of the various categories of casino, we are concerned that
the Regional Casino limits are too low. If the Government has
concerns over the proliferation of large casinos it should be
pointed out that the total of 5,000m2 can easily be provided.
Indeed this limit will actually encourage the building of such
casinos in larger numbers than envisaged. This would seem to undermine
the suggestion that the total number of regional casinos will
be modest. We would advocate a higher minimum for this category
more in line with the realities of modern casino development.
MACHINES AND
MACHINE RATIOS
10. As the majority of the members of the
Bingo Association are not casino operators we do not wish to get
too involved in the discussions over the allocation of gaming
machines to the various categories of casinos, as it will be appreciated
that our two largest member companies operate considerable number
of casinos between them. However the development of casinos and
the attraction of the machines that they have is of great interest
to many of our members and there are two aspects of the Government's
response upon which we wish to comment.
11. The Association understands the Government's
rationale in limiting the number and type of machines in large
casinos, which follows the industry's arguments regarding "trading
up" for bingo players to harder gaming products. However,
the separation proposed between small and larger casinos, including
the different machine ratios, may act to encourage the development
of large, as opposed to small casinos, and may not reduce the
number of casinos overall.
12. Under the automatic and remote casino
terminals section (paragraphs 9-14 of the annex) there is some
explanation of how these terminals will be defined. Paragraph
12 states that "player positions linked to apparatus in the
first or second groups (which are mentioned above) could be sited
on the table gaming floor. But they would not count against the
casinos total of gaming tables or against its total of gaming
machines". This would seem to suggest that casinos that operated
under the first and second groups could be unlimited in number.
This is probably not what the paragraph means but we would hope
for some clarification on this point.
July 2004
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