Commenter:
Richard Hueston, Bingo Gaming Systems Inc.
Comments on Electronic Pull Tab Proposals
Bingo Gaming Systems Inc. (BGS) is pleased to repond to the Department's proposals for electonic pull tab gaming.
We would like to put forward the following comments.
1) The limitation of $25,000 on gross annual gaming receipts per machine is low. This would amount to only $68 per machine per day for a seven day a week operation. For such facilities, the $25,000 limit could be reached relatively early in the year.
2) If the intent of the Department is to mandate a central server that controls all machines at all facilities from one state-owned or regulated location, BGS would argue that the implementation of such would be cost prohibitive. The State could obtain similar levels of security by requiring a site-specific server that would control all machines within that site. These servers would then be required to transmit all required information to the Department through a secure web-based FTP site.
3) The requirement to play $1 wagers on an electronic pull tab machine is in our view artificially restrictive. This would preclude deals featuring other price points such as 25 or 50 cents, or $2.
4) BGS agrees with the prohibition of spinning wheels forming part of any machine's apparatus. However, BGS believes that the use of flashing lights or sound effects can augment the player experience. Just as a winning ticket in a paper deal features bright colors to indicate to the player that he/she has one instantly, the use of visuals and/or sound to provide the same capability in an electronic setting should be permitted. The absence of spinning reels or a pull handle should be sufficient to differentiate a pull tab machine from a conventional slot machine.
5) The payout range of 50 to 75% may be acceptable in paper-based pull tab gaming; however, the upper limit is in our opinion not high enough in an electronic setting to stimulate the churn necessary to deliver a reasonable return to the state and the charities.
