Brad Polley First Street Charity Bingo Association President. Key Issues

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1 _Comments on the Recommendations of The Bingo Task Force To Board of Control Submitted by: Mark Rogers OwnedOperat o r Lucky Days Bingo 539 First Street London, ON N5V 1Z Brad Polley First Street Charity Bingo Association President 539 First Street London, ON N5V 1Z5 Key Issues The Bingo Task Force members being unfairly biased in favour of the Recommendations presented Reduction of Bingo Events in the City and why First Street Charity Bingo Association and Lucky Days Bingo is opposed Adopting the Recommendations will create an unequal business model for the industry in the City of London

2 January 12,2005 Submitted to Board of Control for its consideration regarding the Bingo Task Force Recommendat ions, Bingo has been an important knd raising initiative for local charities since the late 70 s and Lucky Days Bingo has been a part of that process since Recently, the impact of slot machine gaming and noli-smoking by-laws has decreased both charity and hall operator revenue. This problem is not unique to London. In 1997 over 200 commercial halls exited in Ontario, Today, that figure has been reduced to approximately 100. In the City of London, 5 halls currently operate under 3 different owners - a 37.5% decrease f?om the 8 commercial halls that operated in The Bingo Task Force Recommendations suggested to Board of Control, we believe, are neither beneficial to the charities or to the City, As a single hall owner and operator, we also believe Mr. Williams suggestions will benefit 2 of the 3 operators and create an ud& business situation that the City will unknowmgly endorse. Bingo Task Force, Overview: The Bingo Task Force was formed on June 28,2004 in order to inake positive recommendations to the City on changes to the bingo industry that would benefit and protect all parties involved - charity groups, the City Clerk s Office (who collect license fees), players and hall operators. Specifically, the Task Force was to comment on the existing bingo licensing process. The Task Force includes: Chair Gary Williams, PalaceKastle Bingo Owner Jack Walip, Bingo Country Lyle Street and Bingo Country Dearness Drive Operations Manager Tony DeMaria, Charity Representatives Peter Lynch and Murray Wood, City Administrative Representatives Kevin Bain and Michelle Smibert, and CAPS Chiair David Winniger. Invited to attend but not officially recognized: Lucky Days Bingo Owner Mark Rogers (the 3rd of only 3 hall owners in London) or any representative fiom the First Street Charity Bingo Association. Please note: the Bingo Task Force Recommendations were agreed upon by its membem who %formally voted - all representatives from Bingo PalacdCastIe and its charities and Bingo Country Dearness and Lyle and its charities, At the time of the Bingo Task Force Meeting, Cameron Rogers - representing Lucky Days Bingo and the First Street Charity Bingo Association - made our abjections to the recommendations clear. This was noted at the meeting. 1

3 Agenda [Fern # Page # What the Task Force is recommending; 1) Keeping license fees at $75 per event until such time as the number of players per event rises to ) Adjust the City Clerk s budget to reflect the revenue fkom the reduced license fee. 3) Updating and refiig the reporting procedure to the City Clerk s office to reduce the extra work involved h rn incorrect chanty bingo reports. 4) A. Limit the nurnber of bingo events per week to 30 (6 events per hall), rather than 35. B. Permit hall consolidation (i.e. Merging two halls into one location but permitting one merged location to hold 10 events per week versus the current 7 events). C. Any requests to open additional bingo hall locations should be subject to a fill public participation meeting by the CAPS Committee and subsequent decision by Council. Recommendations 1 2 & 3 were all agreed upon by both charity representatives and hall operators in order to help the bingo industry. By maintaining the existing $75 fee, the City saves the charity group $66 for every bingo event they operate. A group operating 14 sessions per year would save an additional $924. Many municipalities in Ontario have received similar requests from bingo industry members because the municipality is able to determine its own license fee. In exchange for the license ke consideration, hall operators and charity representatives agreed to improve the application and reporting procedures. This is an effort to minimize the worlcload required by the City Clerk s Office in handling the paperwork generated fiom bingo reports. 4 A, I-. Limiting the Number of Bine0 Events Der Week to 30 The current City by-law allows each hall operator up to 7 bingo events per week. What Mr. Williams recommends is reducing that number by 1 per hall - for a total of 30 sessions per week instead ofthe current 35. He suggests that decreasing the number of events would increase attendance for the remaining events. The Problem: This assumption is just not accurate and attendance figures suggest otherwise. In 2001 when 3C s Bingo closed, Bingo Country Lyle Street did not see a significant or sustained increase in its attendance. In 2004, Pot of Gold I & 11 closed and decreased the events in the City fkom 49 per week to the current 35. Last year, Lucky Days Bingo saw a decrease in our attendance of 5 people per session - that coupled with a decrease of 14 events per week by our closest competitor makes Mr, Williams attendance assumption questionable. At this point, individual hall operators and charity associations need to examine their events and decided which are profitable and which are not. Halls can operate up to 7 2

4 events per week - they are in not required to operate a11 7 if they choose otherwise. Bingo Country Lyle Street chooses to close occasionally to not compete directly with other sessions running must-go events on the last day of the month. In fact, Bingo Country Lyle closed 7 of the 10 days of this year s Western Fair - perhaps in anticipation of the decrease in attendance the Fair usually brings to bingo. The First Street Cbarity Bingo Association - the group of charities operating events at Lucky Rays - is vehemently opposed to giving up one event per week. The Association has invested time and effort into advertising, promotion and customer service to ensure all 7 events per week are well attended. Losing 52 events per year is a $ blow to charity revenue - almost $1600 per group. They, nor the hall, are willing to gamble that attendance will magically increase - a direct contradiction to the declines of the last many years. This also equates to n $19 SO0 decrease in licensing revenue to the City. In an exchange with Task Force Chair Gary Williams, he characterized the hall owners as I>laying chicken and trying to wait each other out, or to see who has the deepest pockets to starve each other out. In any event, no one is voluntarily reducing events at their hall, and since charities are involved, the local Council has a duty to protect the charities first, the players second and the halls last, if at all.* I would suggest that in no way are charities in danger, nor is the City responsible for mediating a game of chicken. Bingo charities operate under a system where the entire month s proceeds are pooled and then divided equally among the participating groups. There is no question that charity revenue is down, not just in the City but in the entire province - at no point, however, has any Charity Association not had funds to distribute at the end ofa month of bingo events. If a hall continues to run poorly attended events, it is the hall owner who is penalized. If that hall owner chooses to lose money - not at anyone s expense but his own - why would Mr. Williams suggest an option that cuts license revenue to the City and arbitrarily penalizes charities at a hall like Lucky Days Bingo that has 7 well-attended events per week. In addition, I would ask where the charity concern was when we closed the 3C s Bingo (22 groups lost bingo events in 2001) and the Durston fbmily closed Pot of Gold I & I1 (almost 50 groups in 2003). Many wonderfbl community groups operate without bingo &nds and others have found creative ways to supplement their decreasing revenue. To this point, the City has allowed the muket to decide how Inany halls should operate and we would ask for that to continue to happen - especially given charities are still generating revenue fun bingo. 4 B. - The Citv Should Not Omose Hail Consolidation Mr. Williams has also reconmended that should bingo halls wish to merge into one location, the City should not stand in their way other than to rnanage the number of bingo events at the merged hall. Even Mr. Williams concedes that one could argue this is; not in the best interests of the players and not the preferred choice of the City. Further to this, he suggests a chart that includes: 3

5 Page # Halls Merging into One Location None Two Three Four Five Bingos Events per Week at merged Location Given the structure of the London market, this is the most controversial recommendation I believe the Bingo Task Force could have come up with. This is a suggestion that creates an entirely new dync?mic in the City without taking into consideration more displaced charity groups or the unfair competition it endorses. The l roblem: The hall merger Mr. Williams suggests is not a penalty to halls consolidating (by decreasing their bingo events) but a Get Out of Jail Free Card. Five bingo halls make up the London market. Bingo Country Lyle Street and Bingo Cowtry Dearness Drive are operated by Boardwalk Ganhg and are represented by Tony DeMuia on the Task Force. Jack Halip represents London Bingo Palace and London Bingo Castle - who operate 2 bingo halls under one roof The f&h location is Lucky Days Bingo - owned and operated by the Rogers fbmily. What this recommendation would allow is for the two Bingo Country locations to merge at either hall. Not only would they lose the overhead and staffing costs from one location and the $ Alcohol & Gaming Commission license fee, the new location would gain revenue from 3 extra events, The same consolidation would also apply to London Bingo Palace md London Bingo Castle. These halls operate within the same physical building - being recognized as two buildings by a second municipal address, the floor space being divided by a wall and the additional license fee remitted to the AGCO. Hall consolidation would be most beneficial to the Palace and Castle - the bingo centre where Mr. Williams has gained his bingo experience fkom volunteering. Apart &om the obvious benefits to the 2 owners who voted to approve these reconmendations - this creates an unfair competition scenario that the City will endorse. At the end of a possible merger process only 3 bingo halls would exist - 2 locations that are allowed to operate 10 events per week and one location allowed only 6 events. Nowhere in the province does a situation exist where commercial bingo hails are municipally mandated a dflerent number of licensable events - this is completely unfair to the charities and hall operators of a single location. 4

6 Agmdm Btm # Page # In Summsrv The key issues that Bingo Task Force is recommending are as follows: 1. Limiting the number of Bingo Events to 6 per week At this time, the City Bylaw already allows Hail Operators to chose the number of events they operate - up to 7 per week Reducing events does not guarantee increased attendance at remaining events and penalizes charities operating profitable existing events. There is no need for this to be changed. 2. Allowing Hall Consolidation with changes to the Events per Location This creates a biago market where equal commercial locations will be allowed to operate ;a different number of City approved events. This is not fair to existing charities or hall locations without any consolidation options. There must be some plan in place that will accommodate the equal treatment of all hall operators and charity organization in the bingo industry. The easy choice for Board of Control would be to accept the recommendations of a Task Force headed by a long serving and well-respected former Council member. But thh set of recommendations was approved by only 2 of 3 hall operators and their charity associations - and those owners/associations have a direct benefit fkom the reconunendations. With so few operators, coming to a consensus among 3 operators should be an important part of any Task Force option. The diflcult choice for Board of Control is to decide the Task Force s Recommend;itions are not applicable to the current bingo industry. In 2004, Pot of Gold I and Pat of Gold 11 closed 14 sessions per week and displaced almost 50 charity groups. Two years prior to that, 3C s Bingo closed its doors and 22 charities had to search elsewhere for fhdraising alternatives. In neither case did the City step forward to adopt any changes. It is likely at this point in time there are too many bingo events and not enough players to sustain them, however there is no evidence to suggest this will improve attendance. To this point, the City has allowed the market to decide on its own - with no current risk to the charity groups involved. What we would ask is for the City to remain consistent - allow the bingo nwket to sort itself out like any other industry and treat businesses equally. 5

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