12. Memorandum from Sun International
(GMB 26)
The JSC is being reconvened to specifically
consider the question of the role of regional planning bodies
in the determination of casinos, (Government response to recommendations
79—81, 83—85) and the joint statement by ODPM/DCMS
contained within the Annex of the Government Response to the JSC
Report on the Draft Gambling Bill, 14 June 2004.
Categories of Casino
— We welcome the clear definition of
the categorisation of casinos as contained within the Government
response.
— This statement of intent will succeed
in securing the potential regeneration benefits by setting a marked
boundary between the requirements and permissions within each
type of casino, providing greater security of investment to those
operators looking to establish "regional"" casinos.
Non-Gambling Area
— We welcome the stipulation of the
provision of the non-gambling area as a mature and measured approach
to responsible gaming.
— We are particularly pleased to see
that this will not be a set formula provision in each location,
but will allow the operator to respond to the needs of the local
community in providing non-gaming entertainment.
Planning Issues
— We note that, initially, each RSS
will comprise nominated policies from the existing regional planning
guidance (RPG). In the absence of any explicit guidance relating
to casinos, it may be appropriate to apply the same policy criteria
to regional casinos as to any other major leisure-use, as envisaged
in draft PPS6. This should ensure that, where appropriate criteria
based policies exist, the ability of local authorities to determine
applications for new casinos in their areas against such criteria
should not be compromised.
— We are concerned that there may be
a policy vacuum at the national level about specific criteria,
making it difficult for regional planning bodies to incorporate
appropriate planning policy for casinos.
— We feel that a clear policy statement
from the ODPM regarding, for example, location criteria and required
regeneration benefits is essential if the planning system is to
provide any form of transparency and certainty to an industry
looking to develop casino schemes of a regional scale.
— The only alternative to a coherent
policy framework would be policy derived through call-in decisions,
which is both uncertain and frustrating to an industry looking
for guidance.
— We remain concerned that the issue
of double jeopardy has not been fully understood in the context
of the granting of planning applications and licences for casinos.
This runs counter to the aims of the government in terms of simplifying
and speeding up the planning processes and is likely to result
in unnecessary bureaucratic delay.
— Further clarification is still required
on the role of regional planning bodies, the resolution of conflict
either between competing applications within a local authority
or across a region, the use class order and the role of planning
policy guidance. We remain concerned that, without a structured
approach, the local and regional bodies will be unable to implement
their desired casino strategy for the region.
PPS6
— The revised PPG/PPS6 does not, in
our view give sufficient guidance to either regional or local
authorities in terms of determining the most suitable location
and criteria for a casino.
— We would strongly urge that the ODPM
provide clear policy guidance on what it would expect to see in
proposals for casino developments on a regional scale. If this
cannot be done within the present framework of the PPGs and PPSs
then a specific policy statement would be welcomed.
Use Class Order
— The issue of the Use Class Order
remains open. Whilst we are aware of the intention to prevent
the potential proliferation of casinos through the licensing process,
it is our belief that a change to the Use Class Order, removing
casinos from D2 and then either creating a new class specifically
for casinos, or designating them Sui Generis, will provide an
extra safeguard to this process.
Local/Regional Strategies
— In order to deliver major investment,
companies need to limit their commercial risk by assurances that
their investment will not be undermined by the development of
several large casinos nearby.
— Inevitably, large-scale casino projects
with their complementary facilities will be planning applications
of regional significance. This means that the new Regional Spatial
Strategies (RSS) will become particularly important documents
when assessing opportunities for such proposals.
We understand that the JSC will consider some
of the issues outlined above, however, our concern remains that
the timing of this is crucial in order to prevent the legislation
being undermined.
July 2004
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