To: The Secretary of the Starting Price Regulatory Dated: 13 March, 2016
Dear Jim.
I am writing to you on behalf of the Horseracing Bettors Forum about the Starting Price Regulatory Commission’s report on the Starting Price consultation, which was published a week ago.
As you may have gathered from comments made on television and in a couple of newspapers, HBF was unimpressed by the findings of the report and by the way the consultation was undertaken. I am writing to you now to seek clarification around a few points while HBF considers whether or not it should take the matter further.
HBF notes with approval that SPRC sees an increase in sample size and efforts to increase the anonymity of those included in the sample as desirable. But it is not clear what action will be prompted by this. To whom is it “recommending” that these are good ideas – if it is not itself – and what does “continuing to keep these matters under review” amount to?
HBF is disappointed that SPRC saw no merit in its suggestion of correction to over-rounds, but this process has been useful in establishing the SPRC’s outlook as well as the limits of its powers. HBF asks that SPRC explain why it would seek not to curb excessive over-rounds in the hypothetical case (raised by SPRC) that it was empowered to do just that.
More generally, HBF is significantly concerned about the basis for the consultation itself. It believes that the SPRC’s positional statements before and after the period in which the consultation was open indicated that suggested alternatives to the current system would not get a fair hearing.
SPRC describes SPs as “…a tried and tested system…it does what it says on the tin…” and asks, rhetorically, “…if it ain’t broke, why fix it?” This does not appear to be an impartial and open-minded basis on which to conduct a public consultation, and HBF therefore believes the report is fundamentally flawed.
HBF also believes that the concentration on the 2015 Grand National as a “catalyst” for what some felt was a long overdue consultation was wrong. Concerns regarding the SP system had been raised previously, and it is too easy to dismiss the Grand National as a one-off.
Of even more concern is the SPRC’s attempt to quell concerns about the 2015 Grand National SP on the basis of over-round per-runner, pointing out that it was similar as for racing in general. This is specious and raises significant doubts about SPRC’s fitness for purpose.
Over-round is highly correlated with field-size, a fact drawn to the attention of the SPRC well before the consultation process was even announced. Could you confirm that SPRC was aware of this fact, and, if so, why they chose to ignore it and make such a facile point?
HBF also disputes some of the inferences made by SPRC from what the latter saw as a low response to the public consultation. The response included one from HBF – which had been formed shortly before the consultation closed to represent the perceived views and concerns of the entire horseracing betting public – as well as others from significant bodies within racing and betting.
Even if the response from the general public was low, SPRC has a responsibility to that public, irrespective of whether that public understands a complex issue sufficiently to make representation in large numbers. Does SPRC acknowledge this responsibility?
In a number of places, the SPRC cites its own limitations as a reason not to act. It seems obvious to HBF that a body charged with over-viewing something as fundamental as the integrity of the SP should have commensurate powers or be replaced by a body that does. Does SPRC agree with this, and what, if any, steps is it taking to improve the situation?
Lastly, as specified in HBF’s immediate response to the publication of the report, it wants it on record that it does not favour inclusion of so-called satellite rings in the sample (a suggestion which met with markedly more enthusiasm from SPRC than most others).
These rings, often well away from the main betting action, are generally used “for convenience”, with prices on offer that are unfavourable to the customer as a result. HBF will oppose attempts to include satellite rings in the sample without assurances being in place that the SP will not be adversely affected.
HBF will be making this letter public and asks that SPRC respond to the specific questions raised herein within a month of the date shown above.
Yours
Simon Rowlands
On behalf of the Horseracing Bettors Forum
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