GMB 26 Sun International
Sun International Representations
to the JSC Evidence Session
6th July
2004
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, 14th 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.
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