“A renewed call for betting to be allowed in pubs and clubs is one of the key recommendations in the British Horseracing Boar?_x0019_s submission to the Gambling Review Body, published today.
This initiative, removing the current distribution monopoly enjoyed by the off-course betting industry, would allow for increased revenue for Government, Racing, the punter and the betting industry resulting from greater consumer choice and reduced costs of providing betting facilities outside Licensed Betting Offices (LBOs).
BHB has commissioned from Charles River Associates an economic impact study on the effect of betting in pubs, to be submitted to the Gambling Review Body later this autumn.
BHB Secretary-General Tristram Ricketts said: “Greater accessibility to betting facilities was one of the key proposals in the BHB’s Financial Plan. We now have the ideal platform on which to promote this initiative as part of a package of measures designed to widen consumer choice and provide improved protection for the punter.
“BHB looks forward to the opportunity to expand upon the content of its submission in oral evidence to the Gambling Review Body.”
BHB supports confining the full range of betting opportunities to licensed premises and to those aged 18 and over. There is also a strong case for making horserace betting available in unlicensed, non-dedicated premises but to allow only certain types of betting opportunity. These might include small-stake, big-win bets on a set number of events, such as the Tote’s Scoop 6, which do not offer the ability for rapid repeat play or the immediate chasing of losses.
Extending the availability of betting facilities into non-dedicated outlets would also present the opportunity to attract a new audience to Racing and betting, including more women.
In the area of Consumer Protection, BHB recommendations include:
? A new authority, with overall responsibility for all aspects of gambling regulation, including betting, should be established, including ensuring appropriate protection for those betting on the Internet
? This new body should examine more rigorously applications for bookmakers’ permits and require them to provide a financial bond before trading
? Gambling debts, owed by both punter and bookmaker, should be treated like other commercial debts and be recoverable at law
? There should be an arbitration body on disputes between bookmakers and punters, along the lines of the current Independent Betting Arbitration Service but its decisions should be binding. All UK-registered bookmakers should be required to agree to accept its decisions as a condition of being granted a betting permit and LBO licence
? Procedures for returning Starting Prices should be scrutinised independently by the proposed new gambling regulatory authority and there should be a clear, binding, unequivocal code of practice
Other proposals include:
? There should be a relaxation of current restrictions on the advertising of betting, particularly on television. Present controls do not allow for the proper promotion of betting and also constrain horseracing’s ability to attract potential new customers
? Section 13 of the Betting, Gaming and Lotteries Act 1963, which governs racecourses’ charges to bookmakers, should be repealed, and racecourses and bookmakers left to come to their own commercial arrangements. These arrangements should require declaration of turnover by bookmakers
? Racecourses should be permitted to operate betting facilities on non-racedays, mirroring those available on racedays and in LBOs, and to offer enhanced gaming opportunities as part of their development as leisure complexes
? There should be increased flexibility in LBO opening hours, to take advantage of the anticipated development of floodlit evening horserace fixtures and global betting opportunities
A copy of the Executive Summary is attached.
The full submission to the Gambling Review Body can be found on BHB’s website at www.bhb.co.uk
1. The betting and gaming environment, British Racing and society itself are very different in nature to four decades ago. Continuing technological development will accelerate further the pace of change.
2. The British Racing industry is a major employer and contributor to Government revenues. Racing and breeding support 60,000 jobs while the betting industry, which relies upon horseracing for 70% of its business, employs some 40,000 individuals. The Racing and betting industries are interdependent in many respects. Revenue from horserace betting is vital to Racing, even at current, inadequate levels. Racing’s long-term future depends significantly on it receiving a major injection of funds from betting.
3. The legislation governing betting on horseracing should be constructed in a manner which:
? Recognises that Racing and betting are separate, but interdependent industries
? Enables an increasingly commercial Racing industry to compete domestically and internationally with other leisure activities
? Reflects changing public attitudes towards gambling
? Allows increased accessibility to horserace betting by new audiences, while providing adequate protection for the consumer in general and the young and vulnerable in particular
? Allows betting on horseracing to take advantage of new technologies
? Ensures that criminal activity is minimised
? Is fair and reasonable in nature
4. Since the legalisation of off-course cash betting, Licensed Betting Offices (LBOs) have enjoyed the status of monopoly distributors of the horserace betting product off-course. Unlike most major Racing nations, British Racing does not itself own or control this means of distribution. LBOs are also an inherently expensive means of distributing the betting product.
5. There is a strong and logical case for extending the availability of off-course betting beyond licensed betting offices into non-dedicated outlets. This would remove the current undesirable distribution monopoly enjoyed by the off-course betting industry and, as a result of the reduction in overheads, present the opportunity for increased revenues for Government, Racing, the punter and the betting industry.
6. The full range of betting opportunities should be confined to licensed premises such as pubs and clubs and to those aged 18 years or over. BHB has commissioned an economic impact study on the effect of introducing betting in pubs and clubs. However, there is also a strong case for making horserace betting available in unlicensed, non-dedicated premises, but to allow only certain types of betting opportunity. These might include small-stake, big-win prizes on a set number of events, which do not offer the ability for rapid repeat play or the immediate chasing of lCopy2
7. BHB commends the work of Gamcare and other agencies dealing with the prevention and treatment of gambling addiction. Designated agencies should attract continuing financial support, at an appropriate level, from the gambling industry itself.
8. A new authority, with overall responsibility for all aspects of gambling regulation, including betting, should be established. This would, inter alia, create greater consistency of approach to licensing issues, assist coherent policy formulation and benefit the public perception of betting and the betting industry.
9. This new body should require bookmakers to provide a financial bond before trading; there should be a central register of bookmakers’ permits; and the procedures for making legitimate objections to the holder of a permit should be easy and straightforward.
10. There should be a relaxation of current restrictions on the advertising of betting, particularly on television, which do not allow for the proper promotion of betting and which also constrain horseracing’s ability to attract potential new customers, whether as punters, racegoers, television viewers or sponsors.
11. There is no logical reason why gambling debts, owed by both punter and bookmaker, should not be treated like other commercial debts and be recoverable at law.
12. There should be an arbitration body on disputes between bookmakers and punters along the lines of the current Independent Betting Arbitration Service) but its decisions should be binding. All UK-registered bookmakers should be required to agree to accept its decisions as a condition of being granted a betting permit and LBO licence.
13. BHB favours a market-based regime in which there is no barrier, artificial or otherwise, to British Racing continuing to be on offer to foreign-based clients, both existing and potential, through the Internet and other electronic and interactive media. It is however essential that British Racing should be in a position to negotiate an appropriate payment from the respective Internet site operators and that, in so far as it is possible, individuals betting through a particular website should enjoy an appropriate level of protection and confidence. A regulatory framework is therefore necessary: a proliferation of gambling sites offering unregulated betting on British Racing is not acceptable.
14. The procedures for returning Starting Prices should be scrutinised independently and there should be a clear, binding, unequivocal code of practice. BHB supports the introduction of an independent race by race audit system as proposed by the Jockey Club. The proposed new gambling regulatory authority should ultimately be responsible for monitoring practices as they relate to SPs.
15. Section 13 of the Betting, Gaming and Lotteries Act 1963 is a non-commercial arrangement which is increasingly anachronistic and detrimental to the further dynamism of on-course betting which the betting ring reforms introduced under the aegis of the National Joint Pitch Council (NJPC) have engendered. It is recognised that at the racecourse there should be a strong on-course betting market and a healthy balance between Tote betting and that taking place in the ring, but Section 13 should be repealed and racecourses and bookmakers be left to come to their own commercial arrangements. These commercial arrangements should require declaration of turnover by bookmakers.
16. Racecourses are under-utilised assets with racing taking place on as few as six days per year and on average around 15-20 days per year. As a controlled gambling environment, it is proposed that each racecourse should be allowed to operate betting facilities on non-racedays, mirroring those available on racedays and in betting offices, and to introduce a commercially viable number of ancillary gaming machines as part of a leisure environment in which, inter alia, food and drink are available. Such deregulatory changes will enable racecourses to increase the use of their infrastructure and assets and enable the Racing industry to have the opportunity significantly to increase its income.
17. As British racing increasingly becomes an international betting medium through electronic media, allied to the attraction of racing being staged so as to permit betting on it in pubs and clubs, BHB supports discretionary evening opening of LBOs throughout the year to enable betting on horseracing when such fixtures are programmed; a later permissible closing time for LBOs, to reflect better the likely future consumer demand for betting and anticipated development of floodlit evening horseracing fixtures; and the ability for operators of LBOs and other licensed premises to apply for permission to remain open to a specified, later hour on particular occasions.
MD say’s (no contact detail, check with JH)