Submission to The Casino Gaming Control Section Department of Justice on behalf of The Kimble Group Bachelors Walk, Dundalk, Co. Louth consisting of:

Transcription

1 Submission to The Casino Gaming Control Section Department of Justice on behalf of The Kimble Group Bachelors Walk, Dundalk, Co. Louth consisting of: Mr James Mc Cann, Managing Director of the Kimble Group Chairman of the Irish Gaming and Amusement association and vice president of Euromat (European Gaming and Amusement Federation) Seoirse Mc Cann, Sales and Marketing Director of Kimble Gaming ltd.

2 1. Opening letter To whom it may concern Firstly thank you for taking the time to read our submission and we hope that you will take into account our experience in the field of gaming in Ireland in particular operating gaming halls and manufacturing gaming machines. Before we propose our recommendations can we first tell you briefly who we are and what we do so that you may understand better our involvement in the industry. Kimble was founded over 30 years ago by Mr James P Mc Cann, from then until now it has in some form or another been engaged in producing, manufacturing, distributing and operating coin operated equipment such as slot machines, video games or multiplayer machines. Currently Kimble Gaming ltd manufactures and distributes video slot machines from their premises in Dundalk and sells not only to Ireland but internationally as well. In 2008 we sold over 300 machines in Ireland and are on course to do the same in We are the only Irish company to exhibit at the International Casino Exhibition in the Earls court in London and have done since it started and before that exhibited in its predecessor ATEI at the same location. This is the biggest Casino and gaming show in Europe and is attended by casino and gaming operators from every corner of the world. The only show bigger in the gaming sector is the G2E in Las Vegas which Kimble have also previously exhibited at in 2005 and Kimble are distributors in Ireland for a number of companies from all over the world including Germany, Bulgaria, Russia and Taiwan. Through sister companies Kimble owns and operates seven gaming halls and private members clubs in Dundalk and Dublin. Currently there are around 500 gaming machines and between 10 and 15 multiplayer machines in operation in these seven clubs. Currently there are over 100 people employed by companies associated to Kimble, all of which James Mc Cann is the Managing Director.

3 2. Report Regulating Gaming in Ireland The Kimble Group were extremely impressed with the report and found the Casino Committee to have done a trough job and understand the needs of the industry. In particular we whole-heartedly agreed with the recommendations listed below and hope that this will be pursued when any law or bill is introduced. Recommendations 4 and 5 with regard the power Local Authorities have in issuing gaming licences. The current situation have seen total chaos in some areas of the country. While the act may be rescinded in some areas it is in full operation in other. In other areas the local authorities have seen fit to one grant a single licence leaving the holder with a monopoly in the area. Recommendation 8 and 25 with regards the distinction between gaming and betting and in particular the allowance of gaming machines or FOBT machines in betting shops. This was introduced in the UK so far all reports show that it has a negative impact on society in general. In Ireland at the time of going to print the report states that there are 1170 betting shops in Ireland. At present there are closed to 1800 and if all of these premises we allowed even just two machines the results would be over whelming. That would mean close to 4000 gaming machines spread over nearly 2000 locations through out the country. We believe this situation would be impossible to control and would have a negative impact on both the gaming and betting industry and on society in general due to the level of access that would be available. Recommendations 13 and 14 with regard the licensing Regime. As both an operator and manufacturer of gaming machines we at Kimble know how important it is for operators to feel that the people supplying the machines and carrying out any work on the machines are trustworthy and more then capable of doing the job intended. It should also be a concern for any governing body that the same applies to ensure that the players know that they can trust the industry. We highly recommend that all companies and senior staff involved in the operation, manufacture, maintenance, installation or any position where by they have technical access to the machines be licensed to prove their suitability to work in such an important role. Recommendations 19 and 20 with regard the Age limits and allowing Intoxicating Liquor in Gaming Premises. Kimble highly recommends through their years of experience especially when it comes to Gaming Halls that the minimum legal age should be 21. We believe that this is current practice through out the country at present and is preferred to an 18 years limit by operators. If for whatever reason the limit is set at 18 years then we ask that the operators be allowed up the age limit to 21 at their discretion, which we feel most will inevitably do. We agree whole heartily with the report that intoxicating liquor not be allowed in licensed gaming premises.

4 3. The influence of the UK gaming act on the report One of the most worrying aspects of the report however was how much it seemed to be influenced by the current UK law in particular the 2005 Gaming act. What the report failed to mention however is that this act is solely responsible for the demise of the UK arcade industry which has seen a huge rise in arcade closures since the act was introduced. Firstly we would like to point out the main differences in a market like the UK and Ireland, primarily the population size makes it unfair to compare the markets with London alone having over 7 million people compared to just over 4 million in Ireland. The casino (private members clubs) industry in Ireland is based on a localised industry with most of the club having less then 6 gaming tables. To the best of our knowledge none of the clubs in Ireland are of the size recommended in the report (of type A1 even without looking at type A) and we believe that most towns and even cities in Ireland could not accommodate or support a club or casino of this size. In fact we believe that even in Dublin a club of this size would struggle to attract enough customers to justify its existence. The gaming halls in England have been under serious financial threat since the act was introduced. It is impossible for them to compete in the gaming and betting market with the restrictive limitation placed upon them. Simply put why would a player continue to bet 50p to win 25 (odds of 50/1) when they can play on line and get much better odds. Even placing a bet such as a lucky 15 or Yankee in the betting shops offers much better value for players. This coupled with the introduction of FOBT machines in the UK betting shops has crippled a once very strong industry. As a company who have first hand dealings with a lot of UK manufactures and operators we have seen first hand how they have suffered while other area of the gaming and betting industry have been allowed to blossom. One significant factor which must be mentioned is the fact that most of the revenue obtained in the UK from gaming machines comes from Category C (AWP) machines. There are between 150,000 and 200,000 of these machines around the UK the bulk of which are located in Pubs, truck stops, chip shops etc. This gives underage and vulnerable people easy access to gaming machines. The report has recommended that this not be allowed to happen in Ireland, which Kimble agrees with. But it must be noted that with out this market most UK companies would be out of business because of the strangle hold the limited stake and prizes set out in the 2005 gaming act have put on them with regards to gaming halls and arcades. We believe that to have a vibrant yet well regulated market licences gaming halls and casinos must be able to compete with other forms of gaming and betting. Following the UK in there laws will not create this. Enclosed is a letter from the UK MP Tobias Ellwood to his party colleagues in which he express the state of the industry since the introduction of Gaming Act and notes that the limits on states and number of certain classes of machines are to restrictive. We believe that his change do not go far enough to try to return the UK market to its former height. Note this letter was sourced from the BACTA website. We hope that the Irish industry will not simply become a copy of the flawed UK industry.

5 4. Recommendations Kimble would like to see incorporated in any law introduced. 4.1 Electronic Casinos The biggest area on which the report totally neglects to mention is that of electronic casinos. Most countries in Europe and abroad have provisions for the operation of electronic casinos, these are a mixture of gaming halls as laid out in the report and live casinos offering tables games. The difference being that the tables games are operated by automatic machines. Most commonly the tables games found in these locations are roulette and blackjack but other tables games are available. This is the largest growing sector in the industry and has even begun to appear in the UK with the opening in Leeds of Grosvenor casinos first electronic casino. Most arcades in Ireland already model them selves on this format. We cannot stress enough how important electronic casinos would be for the industry to survive. The electronic casino would offer gaming machines with the same limits as live casinos as well as automated roulette and other table games. 4.2 Stake and win allowed on gaming machines For any gaming industry, which evolves from the passing of a new law to survive, it must be competitive with other forms of gaming and betting available in Ireland. Currently any player wishing to have a bet in Ireland may do so under a number of different forms including the National Lotteries (lotto and scratch cards), betting shops both on and off course, Bingo halls and online casinos. In the case of all the above there is no restriction by law as to how much a person can stake or how much they can win. While we do not expect the gaming machine industry to be given such liberties we would however hope that the limitations placed by any law allow us to compete with all the aforementioned outlets. Today I can walk in to a betting shop and place a 20 Yankee or Lucky 15 on either football or horseracing or even place 5000 on a 100/1 outsider in a race without any restrictions and win thousands or even hundreds of thousands in a single bet. Like wise I can go home, sit at my computer and play slot machines or tables games online betting as much as my credit card will allow with no limitation on how much the win amount can be. Kimble would like to see a restrained limit of 5 placed on gaming machine stakes in licensed gaming halls and casinos. This we feel allows operators to compete with other areas of gaming while being restrictive enough to safe guard anyone who might feel the urge to spend more then they can afford. With regards to the maximum win on a machine, we can think of no good reason why a limit would be placed on how much some body can win for their stake. If a person places a bet on the lottery or buys a scratch card they want to win as much as possible without government putting a limit on it. Why then should they be limited to the amount they can get in return for the same value bet on a gaming machine? Restricting the maximum payout on the machine to say 500 turns the odds of the game away from the favour of the player who would surely feel hard done by knowing that on a proper gaming machine they should be able to win up times their stake. It is a fact that AWP or limited jackpot machines need to use a lower game percentage thus shorting the length of time a player gets on the machine for their money and essentially lowering the chances they have of winning. Most AWP or category B machines use a percentage of around 70% a gaming machine with out limit on the payout usually runs some where greater then at least 90%.

6 Therefore giving the player a 20% greater return on their stake making the games last longer and offering a much greater chance of a win for the player. It is the case now also were machines are being linked to a common or progressive jackpot. Would this fall under the same limits? In certain countries machines from multiple casino have been linked to create massive jackpots reaching over a million euros. If multiple machines are linked in a single gaming hall can the jackpot be accumulated? i.e. if there is a max win of 500 per machine can 10 linked machines pay 5000 in the one gaming hall? 4.3 Live casino size One of the most worrying points in the report concerns the attitude the committee has towards the general size a casino should be. Again they point towards a model based on countries were the population is much higher then Irelands. We believe through our experience in the industry the only Dublin could accommodate a casino of the size recommended in the report and even then it would hold only two or three of these in heavenly populated areas. Even large cities such as Cork and Limerick would struggle to sustain a casino with anywhere close to 30 gaming tables. This would create one or two locations holding a monopoly over the country and offer nothing for people living outside the capital or any city where a casino did locate. This could also encourage illegal small casino to open in other areas of the country to provide for people who are not willing to travel so far for their evening s entertainment. The idea of the casino industry opening up is to provide entertainment to the people. There fore it should be available to all people around the country equally and not just those willing to travel miles or those living in large cities. We believe that casinos should be allowed to operate with a reasonable number of tables such at 6 to 8 live gaming tables. This allows local people to enjoy the services offered in their own locality and amongst friends and people from the same locality. 4.4 Gaming Machine Testing It is commonplace in many jurisdictions that any machine going to be operated in the market must pass some kind of regulatory checks. Often gaming machine programme versions must be approved by a testing body in order to be operated in the market. If then any changes have to be made to a programme then it must be tested and approved again. While there are in existence external companies that offer these services for government and state bodies it should be noted that by using these companies the cost of manufactures and operators increases greatly. We believe that if the regulatory body intend to have games tested for approval before they may be operated then a dedicated body should be set up by the regulator. It should be and in house body set up here in Ireland. This allows the manufacturer to work more closely with the regulator and not incur the cost and time taken to ship machines abroad to an external company. Also setting up a dedicated department here creates employment for in Ireland. 4.5 Responsible gaming Euromat (European Gaming and Amusement Federation) are soon to release their guidelines on responsible gaming in Europe. Kimble hope to have a copy of this paper before its release date and will gladly submit a copy to the committee.

7 5. Conclusion We strongly urge the committee or resulting state body to carefully consider the outcome of any regulation they propose. Key factors of the regulation will certainly determine the success or failure of any resulting industry. In particular the stake and win amounts allowed must be able to compete with other forms of gaming. Also the licence fees and procedures should be put in place so as not to cripple or obstruct any company or person working within the industry. We would also ask that when the time comes we be allowed to present an oral submission to the committee. We are available for consultation any time the committee may feel the need and hope we can help the committee through our years of experience working within the industry. Yours Sincerely James Mc Cann & Seoirse Mc Cann Care of Kimble Gaming Ltd Bachelors Walk Dundalk Co. Louth TEL: FAX:

8 TOBIAS ELLWOOD MP Dear Colleague HOUSE OF COMMONS LONDON SW1A 0AA Stakes and Prizes of Adult Gaming Machines 26 February 2008 The Conservative Party has called on the Government to review the stakes and prizes of adult gaming machines in order to ensure that the 2005 Gambling Act has not pushed punters towards harder forms of gambling. There have been clear signs that many family seaside arcades have suffered as people move out of these traditionally safer gaming venues. In order to allow Adult Gaming Centres (AGCs) to remain competitive we are recommending two changes: 1. Increase of stakes for category B3 machines from 1 to Increase of category B3 machines from the current limit of four per establishment to a maximum of 20% of the total number of slot machines per establishment. The 2005 Gambling Act reduced stakes from 2 to 1 and placed a limit on the number of B3 machines in any premises. However, the Government cannot produce any evidence as to why these changes were made. Family arcades are a vibrant part of many seaside towns and it is wrong that they have suffered from an unintended consequence of Government legislation. Seaside arcades have suffered huge downturns in trade since the Gambling Act came into force. The British Amusement Catering Trade Association (BACTA) estimates that the sector has experienced a 21% reduction in revenues since 1 September EDM 840 Colleagues are encouraged to sign 840 which calls on the Government to introduce the same recommendations as mentioned above. I hope this is helpful. Yours sincerely Tobias Ellwood

9 NOTES Fixed Odds Betting Terminals We have expressed concerns about the growing popularity of FOBTs which are found in Bookies and can take a maximum stake of 100 every 20 seconds. We have called on the Gambling Commission to conduct a review of their use. On 20 th February Gambling Minister Gerry Sutcliffe finally conceded our point and asked for a review to take place. Colleagues are recommended to visit their local bookies (if you are not familiar with one already!) to see how these relatively new machines work. Review of Gambling Policy This announcement is the first of a series of changes we plan to make in order to amend a number of loop holes in the 2005 Gambling Act. We want to ensure we have fair and enforceable regulation at every level so we can protect those who move from seeing gambling as entertainment; (knowing you are likely to lose) to those who become addicted (and think you are likely to win).