Supplementary memorandum from Caeasars
Entertainment (DGB 131)
Caesars Entertainment is submitting this additional
short memorandum of evidence to the Joint Committee on the Draft
Gambling Bill.
Caesars Entertainment has noted a number of
concerns that the Joint Committee on the Draft Gambling Bill has
expressed regarding the current proposal to allow unlimited numbers
of machines in casinos that meet the criteria of "large"
casinos. The proposals in the Draft Bill create a "cliff
edge "between" small casinos which will be allowed a
maximum of 120 machines, and the unlimited number of machines
permitted in "large" casinos. As currently drafted the
Bill could possibly lead to the proliferation of gaming machines
via casinos and we assume that the Committee is seeking to ensure
that some reasonable limitation is imposed to prevent this.
We understand that the Joint Committee has heard
proposals to severely limit the number of machines by, for example,
placing a machine/table ratio of 8:1 for casinos with more than
10,000 square feet of table gaming area and with a minimum of
40 tables. In our opinion, this would only lead to the proliferation
of smaller casinos (40 tables and 320 machines) and make investment
in larger casinos with additional leisure facilities and their
attendant economic development benefits very difficult to justify.
We would therefore suggest that the Joint Committee
consider recommending a more realistic upper limit on the machine/table
ratio as well as linking the total number of gaming machines permitted
in a large casino to the number of table games and the total square
footage of the gaming area as follows:
The maximum number of gaming machines permitted
in any casino should be three times the number of gaming tables
with the following exception:
Up to 30 gaming machines per table may be permitted
in large casinos that incorporate more than 40,000 square feet
of gaming area on one floor, of which a minimum of 40 table games
occupy at least 10,000 square feet of the available gaming space.
Table game—a gaming table
that is manned and available for use for a minimum of 50 hours
per month.
Gaming area—the area in
which table games and machines can be played, including related
circulation and cashier/redemption areas.
We believe that this proposal should limit the
number of machines in a sensible and responsible manner. At the
same time it should encourage substantial investment in a controlled
number of large casinos that will incorporate significant leisure
and entertainment facilities.
February 2004
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