Response to the draft gambling bill

Draft Gambling Bill Consultation
Gambling and National Lottery Licensing Division
Department for Culture, Media and Sport
2-4 Cockspur Street
London, SW1Y 5DH

27 February 2004

Draft Gambling Bill Consultation:  Response by the Fellowship of Independent Evangelical Churches (FIEC)
The FIEC is an association of 465 independent evangelical churches based mainly in England, but also with affiliated churches in Scotland, Northern Ireland and Wales. Our total membership is almost 22,000 with over 30,000 attending the main services of the churches. We welcome the opportunity to comment on the Draft Gambling Bill.

We wish to state at the beginning our objection in principle to gambling. We believe gambling is immoral, addictive and harmful to society. It involves making profit out of someone else’s loss. It directly appeals to greed and covetousness, which is in breach of the Tenth Commandment. 

We therefore oppose the general assumption of the Bill that gambling be considered a ‘normal leisure activity’ in need of large scale deregulation. We believe the law should protect society from the consequences of gambling such as addiction, debt, poverty and crime. We are thus concerned about the measures in the Bill that encourage or enable easier access to gambling. Specific proposals in the Bill which are of particular concern are:

Removal of Membership Requirement
Part 5, Section 73 (5) (a) and 74 (4) (a)
We strongly oppose removing the current provision which requires a casino or bingo hall to be operated as a membership club. The existing law provides for a statutory interval between obtaining membership and playing - an interval which is needed to protect problem gamblers and vulnerable persons who have impulsive urges to gamble. There is particular need for a statutory interval with casinos.  Instant access to a greater range of gambling opportunities will create not only more casualties, but more seriously-affected casualties.

Premises Licensed for the Supply of Alcohol
Part 13, Sections 236, 237, 239
We believe the combination of alcohol and gambling is dangerous and harmful. Alcohol impairs ability to assess risk, which is the very nature of gambling. The Bill proposes that the holder of an alcohol licence should be entitled to have two gaming machines. This is an important change to the present system whereby a separate licence application has to be made. We believe the Bill should retain the principle of public houses having to ‘opt in’for gaming. We therefore oppose Section 239, which automatically allows premises with alcohol licences to have two gaming machines, removing the requirement of having to apply for a permit.

We are also concerned that Sections 236 and 237, entitling pubs the right to allow ‘soft gaming’, will expand the use of gaming in pubs beyond the provisions of the 1968 Gambling Act. ‘Soft gaming’ could easily become ‘hard gaming’. As yet there is no specific limit on the stakes, nor does there appear to be firm guidance on the types of games that qualify as ‘soft gaming’.

Remote Operating Licence
Part 5, Section 72
We strongly oppose allowing remote gaming to be licensed in Great Britain. Remote gaming is one of the most addictive forms of gambling and should not be endorsed. A 2002 study from America found on-line gamblers have the highest level of addiction, and warned that the problem is likely to increase with greater internet access.  We note that the government argues that on-line gambling is already available in the UK through websites registered abroad, and there is a need to regulate it. However the government does not apply this flawed logic to illegal drugs or prostitution, both of which are also available in the UK.  Nor does this argument justify allowing gambling by text messaging, interactive TV and radio.

Betting
We oppose the proposal to allow betting tracks to offer betting on days which are not race-days. This will allow continuous betting, removing the protection for addicts which results from their not being able to bet on days which are not race days. We also strongly object to repealing the ban on Christmas Day and Good Friday racing, which are the main Christian festivals. 

Protection of Children and Young Persons
Part 4, Section 36 (1) and (2)
We welcome the Bill’s commitment to protect the young, and the offence to invite, cause or permit a child or young person to gamble. However, we believe there should be no exemptions from this offence. It is inconsistent to state ‘gambling is for adults only’ while allowing exemptions for perceived ‘low’ risk gambling. We welcome the offence of allowing a young person into an adult gaming area, but object to the term ‘Family Entertainment Centres’, (Part 10, Section 197) which implies gambling is a family activity. Finally, even with new rules to protect young persons, we oppose the lifting of the ban on advertising gambling. The more gambling is promoted and visible in society as a whole the more children will accept gambling as normal. 

Gaming Machines
Part 8, Section 142 (4) (c)
We are concerned about the proposal to allow an unlimited number of gaming machines in certain casinos. We note the concern about problem gambling from such situations highlighted in the Budd Report and caution against this proposal.

Operating Licences
Part 5
We are concerned that the changes to licensing law will lead to an unhealthy and unwanted increase in gaming establishments. We believe the requirement to prove unmet demand and to ensure that it is within a permitted area should remain.

Repeal of Provisions Preventing enforcement of debt
Part 15, 256
We oppose repealing the bar on enforcing gambling debts. This law was introduced to reflect the immoral nature of betting contracts and should remain. It is wrong to treat betting as a normal form of credit. We are concerned at the implications repeal will have on vulnerable persons who cannot control their excessive gambling. A gambler never gambles in isolation. The debts accrued have profoundly damaging effects on the gambler’s family.

References
The Bible: Exodus 20:17
Ladd, G T, Petry N M, ‘Disordered Gambling Among University -Based Medical and Dental Patients: A Focus on Internet Gambling’, Psychology of Addictive Behaviours, Vol.16, No. 1, 2002, pages 76-79
Draft Gambling Bill: The Policy, Department for Culture, Media and Sport, Gambling and National Lottery Licensing Division, November 2003, pg 49, para. 6.23
Gambling Review Report, Department for Culture, Media and Sport: Gambling Review Body, 2001, pages 132-133, para. 23.32