Submission to the Joint Committee on the
Draft Gambling Bill
Professor Sir Peter Hall
Thursday 8 July 2004
1. I am Bartlett Professor of Planning at University
College London and Director of the Institute of Community Studies.
I appear here on behalf of the Town and Country Planning Association
as its President. I also declare an interest as Shadow Chair of
the new Blackpool Urban Regeneration Company in course of formation
to promote regeneration in Blackpool through a masterplan for
casino gambling at a number of locations in the town.
2. My submission concerns the question of casino
sizes, facilities and location. In their First Report the Committee
recommended, and the Government response accepts, significant
differences between the largest casino category (titled "regional"
casinos) and the next category (titled "large" casinos).
The most important concern not the minimum table gaming area (1000
in both categories) but the minimum additional gambling area (2500
m² vs. 0 m²) and minimum non-gambling area (2500 m²
vs. 500 m²). This last is the most important of all, because
it is supposed to distinguish "resort" or "destination"
casinos, offering a range of family entertainment (and therefore
open to children) from ordinary large casinos.
3. My submission is that in its response the
Government have not yet taken full account of the Committee's
conclusion that "the lack of clarity, particularly the failure
of the Department for Culture, Media and Sport (DCMS) and the
Office of the Deputy Prime Minister (ODPM) to have decided where
to draw the line between large and resort casinos, could have
serious consequences" (first report, para. 83). The committee's
concern was that casino licences were being granted without relevant
planning gains having been negotiated.
4. The Government has accepted the Committee's
conclusion that "Given the potential for regeneration from
resort casinos we believe that planning for such developments
should be the responsibility of Regional Planning Bodies…
we reiterate our view that all resort casinos should provide regenerative
benefits. They should be required to do so by Regional Planning
Bodies". It accepts that the number of regional casinos likely
to develop in Great Britain, by reason of the size requirements,
will be relatively low; and that regional casinos are expected
to "offer a destination gambling opportunity". However,
by replacing the term "resort casino" by "regional
casino", the Government has blurred a critical distinction.
A "resort" casino, or "destination casino",
is or should be located so as to attract staying visitors who
will spend more than one night, not only gambling but also enjoying
a range of other entertainment. As the history of Las Vegas shows[3],
this needs to be achieved through a cluster of casinos, typically
by different developers with different proprietors, which achieve
synergy by offering a range of such experiences over a period
of days and nights. Only a resort, located at some distance from
major conurbations, can achieve such a synergy.
5. As the committee recognised in its first report,
there is a special case for privileging resorts in this way. Many
English and Welsh seaside resorts, particularly on the Kent and
Sussex Coasts and in the north of England, have experienced a
long period of decline since they first had to compete with Mediterranean
resorts in the 1950s, and worldwide resorts subsequently. They
built an alternative niche market through short-stay tourism in
the 1970s and early 1980s, but this too has suffered competition
from a wide range of weekend and day-trip destinations including
City Breaks. Ironically, one of Blackpool's main competitors for
tourism is now Manchester. But these resorts are essentially one-industry
towns, as seriously threatened as (for instance) the old textile
towns of Lancashire and Yorkshire. Many of them are now among
the most deprived places in the country on the ODPM 2004 Index
of Multiple Deprivation. Blackpool is 24th most deprived
district authority on average scores and 26th on average
rank; Hastings 38th and 39th; Redcar and
Cleveland 44th, Wirral 48th on average score.
My submission to the Committee that this special degree of deprivation
needs to be specifically recognised at both national and regional
level when considering the location of "regional" casinos.
6. It is therefore very important that advice
on location needs to be more specific, at two levels.
7. Nationally, ODPM should issue specific
guidance to RPBs as to their treatment of regional casinos, in
the form of either a new Policy Planning Statement (PPS) dealing
specifically with casinos, or a modification of an existing PPS
- presumably PPPS 6, Planning for Town Centres, now in course
of finalisation after consultation. This should guide RPBs as
to appropriate locations.
8. One option, which has merit, is reintroduction
of the specific category "resort casino". However, this
meets a problem in that in some regions (e.g. the East or West
Midlands), there are no seaside resort locations while in others
(the North East) there are relatively few; while in others (e.g.
the South East or North West) there are many such locations. To
meet this objection and combine specificity with flexibility,
I would propose the application of a "sequential test",
already familiar in ODPM retail and housing policies, which would
apply somewhat differently from one region to another depending
on circumstances.
9. However, in all cases national strategy should
specify that regional casinos are a quite special and separate
class, operating on a continuous 24/7 basis, and with consequent
traffic and noise impacts, which makes them quite unsuitable for
introduction into mixed-use developments in dense urban areas
in or near the centres of large cities. The experience of the
Sydney Casino, forming a centrepiece of the Pyrmont district adjacent
to Darling Harbour on the fringe of the city's central business
district here, is instructive because it has engendered ongoing
conflicts with the local community. Nationally, PPS will also
need to have regard to the impact of land use classes. In particular,
it may need to withdraw the automatic right to make changes within
the present D2 use class, which would simply allow existing operators
to develop a gross floor space up to 6000 m² without reference
to planning permission, thus bypassing any attempt to develop
a strategy based on a hierarchy of centres.
10. Regionally, following ODPM guidance,
Regional Planning Bodies (RPBs) should develop Regional Spatial
Strategies (RSSs) to the same end.
11. It is extremely important that, at both levels,
ODPM and RPBs take account of the Committee's recommendations
(First Report, recommendations 78, 82, 85 and the final sentence
of recommendation 81): that large and regional casinos be required,
either through the licensing system and/or the planning system,
to contribute leisure and cultural facilities in addition to those
for gambling and, in the case of regional casinos, wider and additional
regeneration benefits. At present, there is no clear guidance
as to how this is to be achieved. In particular, it is vital that
regional casinos should be required to provide an adequate range
of live entertainment.
3 The standard source for the history of American gambling
is David G. Schwartz, Suburban Xanadu: The Casino Resort on
the Las Vegas Strip and Beyond. New York: Routledge, 2003.
See particularly Chapter 7, The Casino Archipelago, pp. 202-205,
for its account of 21st-century Las Vegas as an interlinked
cluster of family-friendly resorts.
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