In Para 9.18 add a line to say "physical barriers to segregate areas should not impede the escape routes from that or other areas".

GAMCARE did not comment on individual policies they were being consulted on but sent through a list of inclusions for either the policy or for licence conditions.

Much of what GAMCARE mention is already in the statement in some way or form and if not can be considered on its merits when dealing with an individual application.

It is suggested that in relation to granting permits an inclusion is made which makes reference to the fact that where the premises comply with the new Gambling Commission Code of Practice there is no reason why a permit should not be granted.

Add a further sentence at the end of Para 20.2 to state "Where premises are applying for additional machines these would normally be granted where the premises comply with the Gambling Commissions Code of Practice".

Where an application is for more than 2 machines it is suggested that Officers have the power to grant up to 4 machines without the need for a hearing.

No amendment required to support this approach.

Transitional Arrangement - The BBPA wish for reference to be made to the transitional arrangements for permits.

It appears that transitional arrangements will be provided subject to any further amendments. Permits will last until current expiry as long as the permit holder remains the same.

Lotteries Council

An individual response was not possible but again some general points were raised.

No proposals to make any amendments to the policy.

Association of British Bookmakers (Submitted by Gosschalks)

In relation to door supervision the ABB are suggesting an addition in relation to Betting Offices "…there is no evidence that the operation of betting offices has required door supervisors for the protection of the public. The authority will make a door supervision requirement only if there is clear evidence from the history of trading at the premises that the premises cannot be adequately supervised from the counter and that door supervision is both necessary and proportionate."

Amendment made and added to the Policy as Para 9.24 - worded slightly different to ABB suggestions to be reflective of general door supervisor issues rather than just betting offices.

A further addition in suggested in relation to betting machines as follows: "While "the authority has discretion as to the number, nature and circumstances of use of betting machines, there is no evidence that such machines give rise to regulatory concerns. This authority will consider limiting the number of machines only where there is clear evidence that such machines have been or are likely to be used in breach of the licensing objectives. Where there is such evidence, this authority may consider, when reviewing the licence, the ability of staff to monitor the use of such machines from the counter."

Amendment made and added to the Policy as para 14.2 - It is deemed not appropriate to state in the policy that there is no evidence that such machines give rise to regulatory concerns.

In relation to re-site applications the ABB suggested: It is hoped that licensing authorities will wish to endorse and support this natural progress and improvement in the industry. It is requested that the policy positively encourage, or at least state that the authority will give sympathetic consideration to, re-sites within the same locality and extensions in order to enhance the quality of the facility provided for the benefit of the betting public.

No amendment required - each application will be dealt with on its own merits.

Enforcement - It is suggested that the following text be added: "The This Authority recognises that certain bookmakers have a number of premises within its area. In order to ensure that any compliance issues are recognised and resolved at the earliest stage, operators are requested to give the authority a single named point of contact, who should be a senior individual, and whom the authority will contact first should any compliance queries or issues arise."

Licensing Objectives - I think a paragraph that LACORS (Local Authority Co-ordinator of Regulatory Services) suggested wasn't inserted here.

ABB suggest an addition at 1.3 to include

1. In accordance with any relevant code of practice issued by the Gambling Commission.
2. In accordance with any relevant guidance issued by the Gambling Commission
3. Reasonably consistent with the licensing objectives and
4. In accordance with the Authorities Statements of Licensing Policies.

Introduction - ABB raised the issue of each Authority inserting its own geographical details.

Responsible Authorities - ABB raised the issue of placing addresses for each Responsible Authority on their website

Children in Betting Offices - The ABB make the following point: At paragraph 14.1 of the draft policy there is a statement which indicates that "this Licensing Authority will, as per the Gambling Commissions Guidance, take into account the size of the premise, the number of counter position available for person to person transactions, any ability of staff to monitor the use of the machines by children and young persons (it is an offence for those under 18 to bet) or by vulnerable people, when considering the number/nature/circumstances of betting machines an operator wants to offer".

Accepted and included in policy.

The above paragraph is a reflection of Section 181 of the Act. We respectfully submit that this paragraph should be qualified with a statement that children are not able to go into betting premises with the benefit of a Betting Premise Licence. In those circumstances it is hard to see what relevance that ability of staff to monitor the use of machines by children could possibly be

This provision is intended to ensure that any unauthorised young persons entering betting premises can be clearly identified. The wording of para 14.1 has been amended accordingly in that the word 'monitor' has been removed and replaced with identify and prevent.

British Casino Association

General points made in relation to door staff and under 18's access to premises.

The BCA state that licence conditions will not be necessary to prevent access to machines.

No suggested amendments arising from this response.

Individual Responses to Tameside MBC Consultation

7.

15.9.06

Association of British Bookmakers

The issues raised are reflective of the ABB response to the AGMA document.

Changes as outlined in No. 5 response above.

8.

23.9.06

Credit Union - Hyde District Assembly

Who makes up the safeguarding children's board and to whom do they report

This is outside the scope of the policy.

The decision outlined at 5.4 is totally wrong and must be reconsidered, as this will prohibit some genuinely interested parties from voicing their opinions.

Paragraph 5.4 clarified to specifically include individual residents.

In relation to the principles on the exchange of information, more information will be needed once it is available.

No further guidance issued therefore review/update cannot be provided at this stage. The Policy will be reviewed at a minimum of every 3 years.

The scheme of delegation indicates that when objections are received, matters will go to full Council, that is acceptable.

Respondents reading of scheme of delegation is mistaken - the scheme of delegation reflects the Gambling Commission's guidance. No amendment made.

In relation to premises licences, it is absolutely essential that children and vulnerable persons can easily be excluded from areas where they should not be, so segregation and monitoring of doors is a must.

No amendment required. Covereed in 9.12, 10.2, 11.2, etc.