Virginia Regulatory Town Hall
Agency
Virginia Lottery
 
Board
Virginia Lottery Board
 
chapter
Casino Gaming [11 VAC 5 ‑ 90]
Action Promulgate new regulation governing casino gaming
Stage Proposed
Comment Period Ended on 12/24/2021
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12/21/21  7:02 pm
Commenter: Erika DiNapoli, Government Affairs Analyst BMM Testlabs

Submission of Equipment Trial Period Section 11VAC5-90-150 (C)(7)
 

Good day, Thank you for the opportunity to comment on the Casino draft regulations. BMM as a gaming equipment testing laboratory is always happy to contribute to regulation reform.  Please feel free to contact me with any questions that may arise. I am happy to assist. -Erika DiNapoli

Quote from Standard: 11VAC5-90-150 (C)(7)

a. A trial period shall be of a scope and duration the department deems appropriate to assess the operation of the prototype or modification in a live gaming environment; 

BMM Test Lab Feedback:

While not relevant to BMM as an ITL, we observe this to be inconsistent with the industry. Best practice is to apply a maximum duration for a field trial.  

 

The Board may want to consider the following language:

a. A trial period shall be of a scope and duration the department deems appropriate to assess the operation of the prototype or modification in a live gaming environment not to exceed XX days without prior notification to the manufacturer and facility operator; 

 

CommentID: 117427