Illinois sports betting regulators are looking for a lot of input before they roll out rules and license operators. In the last week, the public-comment period opened by the Illinois Gaming Board closed and a Request for Information put out the by Lottery also closed. The public comment period ended Sept. 27, and while the IGB has not yet released any of the comments or replied to a request to do so, Crain’s Chicago Business on Wednesday reported that Chicago’s five major professional teams — the NFL’s Bears, Major League Baseball’s Cubs and White Sox, NBA’s Bulls and NHL’s Blackhawks — got together to offer their suggestions to the IGB.
The teams retained the law firm of Fox Rothschild to write the letter in response to SB 690, a massive capital bill that included a gaming expansion. Sports betting is a just a small part of that bill, but stands to have major financial implications for Chicago professional sports teams, and the neighborhoods they are located in.
The spirit of the new law is that the pro teams can open on-site sportsbooks and offer mobile sports betting within their venues. But the language of the law is causing some angst. A key request in the letter is clarification of what entity can actually open a sportsbook at a pro venue.
Fuzzy definitions
According to the letter, the law allows for a master sports betting license to be “issued to a sports facility or its designee,” but does not specifically state that the team itself can get a master license. A sports facility that accommodates 17,000 or more can apply for a master license, and the law allows for seven such licenses.
Seven Illinois sports venues eligible for sports betting licenses:
Wrigley Field
Guaranteed Rate Field
Soldier Field
United Center
SeatGeek Stadium(Chicago Fire)
Joliet Speedway
Metro East St Louis race track— Joe Ostrowski (@JoeO670) June 3, 2019
In the letter, the teams are seeking legal clarity on who could apply for, and ultimately own the master license, and suggest that the intent of the law is for the sports teams themselves, not the facilities, to hold master licenses. Further, the teams suggest that should a team move, the master sports betting license should be able to follow the team to a new venue within Illinois — not stay at the original venue.
Another key concern — similar to in Washington, D.C., where that new sports betting law creates a two-block exclusion area around professional sports venues — is how the term “block” will be defined for the purposes of the new sports betting law. In the letter, the teams also point out that the use of the terms “block” and “radius” are at odds: “while radius is a circular dimension, a block is typically a square dimension. Clearly, the Act intended the curved dimension as the radius or it would just have said ‘within five blocks’ of a sports facility.”
The teams go on to suggest that regulators adopt the 660-foot measurement used by the city of Chicago’s Department of Transportation.
In considering the 660-foot rule, will the five-block exclusion zones of any of Chicago’s pro sports venues overlap? In looking at a city map, it appears that the two venues that are closest to each other are Soldier Field and Guaranteed Rate Field. According to GoogleMaps, these sites are three miles apart in terms of driving directions, but certainly closer as the crow flies. Though this question was not asked by the pro teams — would the 660-foot measurement suggested by the pro teams create overlap of exclusion zones in any case?
Teams: $10 mm licensing fee too high
Among the other suggestions in the letter:
- Prohibiting sports betting, both at physical locations and on mobile apps, within a five-block radius of a professional sports stadium;
- Prohibiting marketing and advertising from competitors within the same five-block radius, unless a team gives permission;
- Prohibiting the Lottery, which will be allowed to run a pilot program at thousands of kiosks throughout the state, from offering sports betting at those kiosks within a five-block radius of the stadiums;
- Considering lowering the $10 mm licensing fee;
- Allowing for patrons to register in person (as required by law) at only one outlet should a company own multiple sportsbooks, either mobile or physical;
- Allowing for multiple “outposts” for sports betting within each venue and within the requested five-block radius;
- Clarification that biometric data regularly collected by teams not be used in sports wagering.
#Chicago! We're looking for males ages 25-59 to participate in a paid focus group about #sports betting taking place the week of October 14. You can earn $100 for 2 hours of your time. Take the survey to see if you qualify: https://t.co/P1Dl3tF71O pic.twitter.com/vlfjQfAfD6
— Focus Pointe Chicago (@FocusGroupCHI) October 2, 2019
Lottery wants help learning about sports betting
While the IGB considers the comments from the leagues, who are key stakeholders in sports betting, the Lottery is looking for a partner to help it navigate the state’s venture into sports betting.
“The Lottery is publishing this [request for information] to learn more about how a governmental organization should engage a vendor to implement and operate lottery sports wagering in a retail environment,” the RFI, which closed Tuesday, reads.
According the RFI, the Lottery is seeking feedback on how it should craft a Request for Proposal for operators to the run the Lottery’s pilot program. While the RFI specifically states that respondents won’t be paid, nor will it choose a vendor through the RFI process, the Lottery requests that “respondents should offer innovative ways to increase and, more importantly, broaden playership associated with, or complementary to the Lottery’s traditional offerings.”
What kinds of companies would respond to the RFI? Think consultants, who could offer top-to-bottom advice, but also potential operators, payment processing companies, risk managers, really any company involved in sports betting that is willing to take the time to share its knowledge with the Lottery.
According to the RFI, the Lottery is seeking advice on everything from tax structure to where best to locate kiosks to sportsbook management and everything in between.
