HarrahS,, PHILADELPHIA CASINO AND RACETRACK

November 9, 2017

R. Douglas Sherman Chief Counsel of the Board's Office Pennsylvania Gaming Control Board

Dear Chief Counsel Sherman:

Please accept this letter as Chester Downs and Marina, LLC's ("Harrah's Philadelphia") response to Executive Director Kevin O'Toole's letter dated November 2, 2017, soliciting input regarding the establishment of a repayment schedule for certain legislatively appropriated loans as required by newly-amended Section 1901.1 of the Pennsylvania Race Horse Development and Gaming Act (the "Act").

As noted in Mr. O'Toole's letter, Act 42 of 2017 imposes a requirement that repayment of $36.1 million in loans appropriated by Section 1901 of the Act (the "Start-up Loans") must be made by licensed gaming entities starting January 1, 2018 and must be completed by June 30, 2019. Payments must be assessed to licensees "in an amount that is proportional to each slot machine licensee's gross terminal revenue". Harrah's Philadelphia respectfully offers the following suggestions regarding repayment of the Start-up Loans:

Frequency. Licensee payments should be assessed on a quarterly basis. Assuming a January 1, 2018 start date and payments on the first day of each quarter thereafter ( excepting only the final payment, due on June 30, 2019), this schedule would result in 7 gross installments of approximately $5,157,143 each.

Allocation Method. Allocation of payment among licensees should be based upon trailing 12 month's GTR of each licensee relative to that of all operating licensees, recalculated at the time of each payment. Capturing a full annual cycle will help to ensure a more accurate view of normalized GTR without unduly emphasizing peaks and valleys that might occur during a 12-month cycle.

In our view, no portion of the assessment for the Start-up Loans should be based upon or otherwise take into consideration a "GTR all time" assessment. As you are aware, "GTR all time" was one component used in structuring the repayment of $63.8 million in loans appropriated by the legislature for agency operations in 2007 through 2010 (the "Operating Loans"). Such loans were appropriated to ensure that the limited number of early entrants in the market would not be assessed for the entire operating cost of the regulatory system until additional operators commenced operations. The Board reasoned that in this way, the Operating Loans disproportionately benefitted such early entrants

51767506.vl

and repayment of the Operating Loans should take such disproportion into account. No such logic applies in the case of the Start-up Loans.

As noted in your letter, the Start-up Loans were appropriated for fiscal years 2004

through 2006 to fund the initial staffing of the Board and its sister agencies responsible for regulation of gaming, as well as the creation of regulations and the licensing processes attendant thereto. During this period, no casinos were in operation.

Operating on the same premise, future properties are benefitted by the Start-up Loans to the same degree as existing licensees and should share in the cost of repayment. We suggest that a "recapture" mechanism should be instituted to ensure that new facilities coming to the market will be required to pay a proportionate share of the Start-up Loans, and that appropriate portions of such payments should be allocated among those licensees who have already paid their pro rated share of the Start-up Loans. Such a mechanism could calculate payments for a new entrant on the basis of the first normalized year's GTR.

Thank you for your consideration, and please contact me with any questions you may have in this regard.

VTY

Chris Albrecht, SVP and General Manager Harrah's Philadelphia

Page 2

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BETHLEHEM

November 8, 2017

R. Douglas Sherman Chief Counsel, Pennsylvania Gaming Control Board Pennsylvania Gaming Control Board P.O. Box 69060 Harrisburg, PA 17106-9060

R .. ECC:'-./ LO

NOV 1 3 2017

PGCB OFFICE OF Cl IIEF COUNSEL

Re: Amendment to PA Race Horse Development & Gaming Act

Loan Repayment Schedule

Dear Mr. Sherman:

Please accept this letter as the response of Sands Bethworks Gaming, LLC d/b/a Sands Casino Resort

Bethlehem ("Sands") to Executive Director O'Toole's letter dated November 2, 2017, requesting Sands'

input regarding the PA Race Horse Development & Gaming Act Loan Repayment Schedule.

We at Sands believe the repayment schedule should be structured the same way as the previous loan

repayment schedule. The terms that we suggest include:

• The amount due should be calculated as a percentage of the industry's total Gross Terminal

Revenue, both historically since inception and over the current fiscal period.

o 50% weight factor - Licensee's cumulative GTR since inception / statewide GTR since

inception

o 50% weight factor- Licensee's current fiscal period GTR / statewide current fiscal period

GTR

• Loan payments should be paid quarterly and would be due on the first business day of each

quarter. For the purpose of this exercise, those dates would be:

o January 2, 2018 o April 2, 2018 o July 2, 2018

o October 1, 2018 o January 2, 2019 o April 1, 2019

77 Sands Boulevard. Bethlehem, PA 18015 484.777.7777 Pa Sands.corn

We at Sands greatly appreciate the opportunity to offer the Board this feedback and look forward to

arriving at an arrangement that is amenable to all Pennsylvania casinos.

If we can be of any further assistance, please do not hesitate to contact us. Thank you.

Sincerely,

Brian R Carr

President & Chief Operating Officer

WASHINGTON TROTTING ASSOCIATION, LLC 210 Racetrack Road

Washington, PA 15301

November 13, 2017

VIA FEDERAL EXPRESSS AND E-MAIL

R. Douglas Sherman, Esq. Chief Counsel Pennsylvania Gaming Control Board 303 Walnut Street Commonwealth Tower 5th Floor, Strawberry Sq. Harrisburg, PA 17101 E-mail: rsherman@pa.gov

Re: Amendment to PA Race Horse Development and Gaming Act Loan Repayment Schedule

Dear Mr. Sherman:

Washington Trotting Association, LLC, a Delaware limited liability company and the operator of The Meadows Racetrack & Casino (the "Meadows"), is in receipt of the letter dated November 2, 2017 from the Pennsylvania Gaming Control Board (the "PGCB") regarding the Amendment to PA Race Horse Development and Gaming Act (the "Act"). The Amendment to the Act affects the obligation of slot machine licensees to repay certain monies initially appropriated to fund three of Commonwealth's regulatory agencies beginning July 5, 2004.

In response to the PGCB 's request from input from each slot machine licensee, Meadows respectfully submits that the method that each licensee would be responsible for paying should be based upon gross terminal revenues of each licensee for the last fiscal year ending on June 30, 2017 as a percentage of total gross terminal revenues of all licensees for the fiscal year ending on June 30, 2017. The Meadows further proposes that the loans should be repaid quarterly through June 30, 2019.

We believe that using the fiscal year ending on June 30, 2017 is the most fair and equitable method of establishing the total annual repayment schedule because it accurately reflects the gross terminal revenues that each licensee has earned given that each of the markets for gaming is sufficiently mature at this point to establish the gross terminal revenues. Each licensee would not be able achieve these levels of gross terminal revenues without the prior $36.1 million loan that is now to be repaid by the licensees.

We have enclosed with this letter a chart with the proposed repayment schedule.

We appreciate this opportunity to provide comments and thank you in advance for your consideration. If you would like to discuss further, please contact me at (702) 541-7777.

Enclosure

Sincerely, ~-7 /.,7 ... ,,·.-

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Carlos A. Ruisanchez President, Chief Financial Officer and Treasurer Washington Trotting Association, LLC

I Methodology: Based on Last Twelve Months Ended Fiscal June 2017 j

Gross Terminal Loan Revenues % of Total Reeai'.:ment

Mohegan Sun $208,562, 173 8.9% $3,222,861

Parx $386,589,505 16.5% $5,973,874

Harrah's Philadelphia $200,372,009 8.6% $3,096,300

Presque Isle $112,001,403 4.8% $1,730,731

The Meadows $217,910,016 9.3% $3,367,311

Mount Airy $142,220,078 6.1% $2,197,692

Penn National $209,682,586 9.0% $3,240,174

Sands Bethlehem $304,160,285 13.0% $4,700,115

The Rivers $265,345,394 11.4% $4,100,318

Sugar House $178,910,324 7.7% $2,764,658

Valley Forge $80,228,728 3.4% $1,239,755

Nemacolin $30,170,007 1.3% $466,210

Total $2,336,152,508 100.0% $36, I 00,000

(

ATTORNEYS AT LAW

November 14, 2017

VIA HAND DELIVERY

R. Douglas Sherman, Chief Counsel PA Gaming Control Board 303 Walnut Street, Strawberry Square Verizon Tower, I 0th Floor Harrisburg, PA 17101

Eckert Seamans Cherin & Mellott, LLC 213 Market Street 8th Floor Harrisburg, PA 17101

RECEIVED

NOV 1 4 2017

PGCB OFFICE OF CHIEF COUNSEL

TEL 717 237 6000 FAX 717 237 6019 www.eckertseamans.com

Mark S. Stewart 717.237.7191 mstewart@eckertseamans.com

RE: Comments from Greenwood Gaming and Entertainment, Inc., regarding Loan Repayment Schedule

Dear Doug:

We write on behalf of Greenwood Gaming and Entertainment, Inc. d/b/a/ Parx Casino ("Parx") in response to Executive Director Kevin F. O'Toole's November 2, 2017, letter regarding the recent amendments to the Pennsylvania Race Horse Development and Gaming Act in HB 271 of 2017, relating to the obligation of slot machine licensees to repay certain regulatory cost loans to the Commonwealth.

As noted in the November 2, 2017, letter, HB 271 amended§ 1901.1 of the Act, 4 Pa.C.S. § 1901.1, to require the Pennsylvania Gaming Control Board ("Board") to establish a truncated schedule to govern the loan repayment obligations of the licensed gaming entities. Executive Director O'Toole identified, and requested industry input on two principal issues that must be determined by the Board in order to set that schedule:

1) the frequency of the payments, i.e. quarterly, semiannually or annually; and

2) the method by which "proportional to each slot machine licensee's gross terminal revenue" is to be calculated, i.e. GTR all time, GTR for trailing quarter or year, or GTR calculated upon some other formula.

These issues are very similar to the ones that were already addressed by the Board in its adoption of the loan repayment schedule in July of 2011. (See PGCB Administrative Order dated July 11, 2011 ). In that proceeding, Parx submitted extensive evidence and legal argument through the submission of comments. (See January 28, 2011, letter from Alan Kohler, Esq., to R. Douglas

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R. Douglas Shennan, Esq. November 14, 2017 Page2

Sherman, Esq.; Comments submitted to Board by Alan Kohler, Esq., on April 28, 2011; Petition for Reconsideration submitted to Board on July 26, 2011 (copies of these documents will be provided upon request)). Parx's comments in that proceeding provide a thorough historical prospective and legal analysis of the regulatory cost loan program that, were this the initial consideration of this matter, should be followed in setting the shortened repayment schedule now.

The regulatory cost loan program was adopted by the General Assembly in the 2006-2007 time frame at the request of the licensed gaming facilities that opened for business the earliest in the Commonwealth, namely Parx, Mohegan Sun, and Harrah's. It was designed to defer loan repayment until all or a critical mass of casinos were opened and then allocate the loan repayment obligations over the entire industry on a pro rata GTR basis as it existed at the end of the deferral period. The sole intent of the loan program from the outset was to protect and benefit early opening casinos, and to keep those facilities from being penalized for opening early and bearing a disproportionate burden of the funding of a comprehensive regulatory system.

Parx continues to believe that it would be the most appropriate for this Board to base the allocation of the loan repayment obligations proportionately on each licensee's pro rata share of statewide GTR at the time that loan repayment becomes due. Not only would such an approach be the most equitable allocation of the costs, it would be consistent with the loan program's sole purpose of protecting the casinos that opened early and provided the value of early tax revenue streams to the Commonwealth.

Nevertheless, because of the extensive process that the Board has already utilized to address the prior regulatory cost loan repayment matter, Parx requests the Board to keep the same formula it adopted by Administrative Order dated July 11, 2011. That formula was the product of substantial industry input and Board deliberation, and it marks a considered balance between the positions of the licensees. Accordingly, Parx requests the Board to utilize that previously approved method to calculate the pro rata share of each licensee.

With respect to the frequency of the payments due, Parx requests that the Board set a schedule consistent with the loan repayment schedule it has already established. Under that schedule, all licensees have the option of either paying the full amount due annually or paying in quarterly payments. Parx believes that maintaining a consistent repayment schedule is important to prudent budgeting of these substantial financial obligations.

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R. Douglas Sherman, Esq. November 14, 2017 Page 3

Parx would like to thank you and the Board for the opportunity to comment on these very important and critical issues. If we can provide you with additional information or assistance, please let us know.

MSS/jls Enclosures

cc: Kevin O'Toole Anthony Ricci Thomas Bonner, Esq.

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s ATTORNEYS AT LAW

November 14, 2017

VIA HAND DELIVERY

R. Douglas Sherman, Chief Counsel PA Gaming Control Board 303 Walnut Street, Strawberry Square Verizon Tower, 10th Floor Harrisburg, PA 17101

Eckert Seamans Cherin & Mellott, LLC 213 Market Street 8th Floor Harrisburg, PA 17101

RECEIVED

NOV 1 4 2017

PGCB OFFICE OF CHIEF COUNSEL

lH.. 717 237 6000 FAX 717237 6019 www.eckertseamans.com

Mark S. Stewart 717.237.7191 mstewart@eckertseamans.com

RE: Downs Racing, L.P.' s Comments on Loan Repayment Schedule

Dear Doug:

This letter is being submitted on behalf of Downs Racing, L.P ., d/b/a Mohegan Sun Pocono ("Mohegan Sun") in response to the November 2, 2017, letter from Executive Director Kevin O'Toole regarding the recent amendments to the Pennsylvania Race Horse Development and Gaming Act's regulatory cost loan repayment schedule.

Specifically, HB 271 of2017 amended§ 1901.1 of the Act, 4 Pa.C.S. § 1901.1, to require the Pennsylvania Gaming Control Board ("Board") to establish a condensed loan repayment schedule to govern the licensed gaming entities' repayment of the regulatory cost loans. Executive Director O'Toole identified two issues that will need to be determined by the Board: "1) the frequency of the payments, i.e, quarterly, semiannually or annually; and 2) the method by which 'proportional to each slot machine licensee's gross terminal revenue' is to be calculated, i.e. GTR all time, GTR for the trailing quarter or year, or GTR calculated upon some other formula." This correspondence provides Mohegan Sun's input and views on these issues.

With regard to the frequency of payments, Mohegan Sun requests that the Board require the payments to be made on an annual basis, with payments due on December 31, 2018 and June 30, 2019. HB 271 requires that repayment of the regulatory cost loans begin by January 1, 2018, and be completed by June 30, 2019; it does not, however, specify the dates upon which the repayments are due. This truncated repayment schedule places a significant financial burden on licensees by substantially increasing their immediate costs. In order to help alleviate this new financial burden, Mohegan Sun believes it would be fair and equitable to permit licensees to retain, and realize the most benefit from, their funds until the end of the repayment period. This payment schedule would comply with the June 30, 2019, repayment deadline set by the

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R. Douglas Sherman, Esq. November 14, 2017 Page2

legislature, and would also allow licensees to have the most control over their funds until that deadline. Accordingly, Mohegan Sun requests that the Board establish a schedule whereby licensees' required payments are due on an annual basis.

With regard to the calculation of the pro rata share of the licensees, the Board has already analyzed this issue in the prior proceeding in which adopted the loan repayment schedule in July of 2011. (See PGCB Administrative Order dated July 11, 2011 ). Mohegan Sun was actively involved in that proceeding and offered substantive input to the Board that remains relevant now. (See January 28, 2011, letter from Alan Kohler, Esq., to R. Douglas Sherman, Esq.; Comments submitted to Board by Alan Kohler, Esq., on April 28, 2011; Petition for Reconsideration submitted to Board on July 26, 2011 (copies of these documents will be provided upon request)).

Mohegan Sun was the first licensed gaming facility in the Commonwealth to open for business, and has been involved in the development of loan repayment issues since the inception of the Gaming Act from both an administrative and legislative perspective. It is critical to remember that the loan program was designed to protect the early opening casinos from being penalized for commencing operations early by assuring that a critical mass of gaming facilities shared in a proportion of these regulatory loan obligations, whether or not those obligations were incurred prior to when a given facility opened for business. The purpose of the program was to benefit and provide an incentive for the gaming facilities that opened early and started providing tax revenue for the Commonwealth, rather than to penalize them through a larger proportionate share of the repayment obligation. Put simply, the program's intent was to assure that casinos that opened earlier than others were not assigned the entire loan repayment obligation during the period until other casinos came on line by requiring that later opening casinos share in the regulatory costs of the industry that Commonwealth agencies incurred before they opened for business.

Given the underlying purpose of the loan program, and equitable principles, it would be most appropriate for this Board to base the allocation of the loan repayment obligations proportionately on each licensee's pro rata share of statewide GTR at the time that loan repayment becomes due. Such an approach would be in line with the goal of the loan program because early opening casinos, which provided the value of early tax revenue streams to the Commonwealth, would not be penalized for opening early.

Nevertheless, because of the extensive process that the Board has already utilized to address the prior loan repayment schedule, Mohegan Sun requests the Board to keep the same formula it adopted by Administrative Order dated July 11, 2011. That formula was the product of substantial industry input and Board deliberation, and it marks a considered balance between the positions of the licensees. Accordingly, Mohegan Sun requests the Board to utilize that previously approved method to calculate the pro rata share of each licensee.

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R. Douglas Sherman, Esq. November 14, 2017 Page3

Thank you for the opportunity to provide these comments. If we can provide you with additional information or assistance, please let us know.

1{~ Mark S. Stewart

MSS/jls Enclosures

cc: Kevin O'Toole Anthony Carlucci Michael Epps, Esq.

{L0714333.l}

DONNELLY LAW attomeysatlaw

A professional LLC

R. Douglas Sherman, Chief Counsel Pennsylvania Gaming Control Board 303 Walnut Street Commonwealth Tower Fifth Floor, Strawberry Sq. Harrisburg, PA 17101

November 14, 2017

RE: Amendment to PA Race Horse Development & Gaming Act Loan Repayment Schedule

Dear Mr. Sherman:

Please accept this letter on behalf of Rivers Casino in response to the November 2, 2017 letter from Executive Director Kevin F. O'Toole regarding the above-captioned matter.

Rivers believes allocation of the repayment should follow the allocation of gross terminal revenue of all of PA's Cat 1, Cat 2 and Cat 3 casinos cumulatively since the inception of gaming in PA. This is consistent with how the statute reads: "proportional to each slot machine licensee's gross terminal revenue." Rivers also believes that it is fair that the first casinos to open pay a slightly higher share as they were able to benefit from not only more revenues, but, perhaps more importantly, a "first mover" advantage.

Additionally, Rivers' believes that any repayment schedule must include the anticipated additional Category 2 casino to be located in Philadelphia, should it be awarded the license prior to repayment of the loan. This because the new casino will benefit along with the existing casinos from the infrastructure, regulatory framework, structure, and educational and experiential foundation established by the regulatory agencies during the startup years of casino regulation in Pennsylvania. Executive Director O'Toole recognizes this in his letter that the deficit was created through expenditures in the creation of an effective regulatory system: "During the start-up phase of the gaming industry which included staffing the regulatory agencies, creating regulations, applications and licensing processes which spanned into late 2006."

Excluding the new casino would result in a "free ride" on this physical, educational and . experiential infrastructure and base. It would, at the very least, be unfair to place the burden of creating the foundation of regulatory governance on only those currently operating casinos.

The new Category 2 predicted in its January 2014 presentation to the PGCB that it would generate $322M in annual gross gaming revenue. This would make it the third or fourth highest

24 Georgetown Ct. Linwood, NJ 08221• P (609) 347-1199 • C (609) 214-2138

revenue generating casino in Pennsylvania. Because it has not benefitted from revenues from the beginning of gaming in Pennsylvania and because it has not enjoyed a first mover advantage, it would not be fair to assess its share of the fee on that number. Rather, we recommend allocating the new licensee an average share of the burden, or 1/13 (as it will be the thirteenth casino) of the repayment.

As to the timing of the payments, we believe that they should be made semi-annually, with the first payment to be due January l, 2018 and the second payment to be due on June 30th, 2018 and thereafter under the same schedule.

Thank you for providing the opportunity to comment on this issue.

Respectfully submitted. •:

'~

Cc: Craig Clark

24 Georgetown Ct. Linwood, NJ 08221• P (609) 347-1199 • C (609) 214-2138

'i I

'

i· / DONNELLY LAW attorneysatlaw

A professional LLC

November 14, 2017 R. Douglas Sherman, Chief Counsel Pennsylvania Gaming Control Board 303 Walnut Street Commonwealth Tower Fifth Floor, Strawberry Sq. Harrisburg, PA 17101

RE: Amendment to PA Race Horse Development & Gaming Act Loan Repayment Schedule

Dear Mr. Sherman:

Please accept this letter on behalf of SugarHouse Casino in response to the November 2, 2017. letter from Executive Director Kevin F. O'Toole regarding the above-captioned matter.

SugarHouse believes allocation of the repayment should follow the allocation of gross terminal revenue of all of PA's Cat 1, Cat 2 and Cat 3 casinos cumulatively since the inception of gaming in PA. This is consistent with how the statute reads: "proportional to each slot machin·e licensee's gross terminal revenue." SugarHouse also believes that it is fair that the first casinos to open pay a slightly higher share as they were able to benefit from not only more revenues, but, perhaps more importantly, a "first mover" advantage.

Additionally, SugarHouse believes that any repayment schedule must include the anticipated additional Category 2 casino to be located in Philadelphia, should it be awarded the license prior to repayment of the loan. This because the new casino will benefit along with the existing casinos from the infrastructure, regulatory framework, structure, and educational and experiential foundation established by the regulatory agencies during the startup years of casino regulation in Pennsylvania. Executive Director O'Toole recognizes this in his letter that the deficit was created through expenditures in the creation of an effective regulatory system: "During the start-up phase of the gaming industry which included staffing the regulatory agencies, creating regulations, applications and licensing processes which spanned into late 2006."

Excluding the new casino would result in a "free ride" on this physical, educational and experiential infrastructure and base. It would, at the very least, be unfair to place the burden of creating the foundation of regulatory governance on only those currently operating casinos.

The new Category 2 predicted in its January 2014 presentation to the PGCB that it would generate $322M in annual gross gaming revenue. This would make it the third or fourth highest

24 Georgetown Ct. Linwood, NJ 08221• P (609) 347-1199 • C (609) 214-2138

revenue generating casino in Pennsylvania. Because it has not benefitted from revenues from the beginning of gaming in Pennsylvania and because it has not enjoyed a first mover advantage, it would not be fair to assess its share of the fee on that number. Rather, we recommend allocating the new licensee an average share of the burden, or 1/13 (as it will be the thirteenth casino) of the repayment.

As to the timing of the payments, we believe that they should be made semi-annually, with the first payment to be due January 1, 2018 and the second payment to be due on June 30th, 2018 and thereafter under the same schedule.

Thank you for providing the opportunity to comment on this issue.

Respectfully submitted. I

Cc: Wendy Hamilton

24 Georgetown Ct. Linwood, NJ 08221• P (609) 347-1199 • C (609) 214-2138

November 14, 2017

Via Email: rsherman@pa.gov

R. Douglas Sherman Chief Counsel Pennsylvania Gaming Control Board PO Box69060 Harrisburg, Pennsylvania 17106-9060

Re: HB271 $36.1 million Loan Repayment Schedule

Dear Mr. Sherman:

Please accept the following on behalf of Mount Airy #1, L.L.C. in connection with the Board's consideration of the $36.1 million Loan Repayment Schedule.

Pursuant to Section 1901 of the Gaming Act, the $36.1 million loan ("Loan") was utilized by the Board, Department of Revenue and Pennsylvania State Police, respectively, to allow those agencies to establish the infrastructure and systems (e.g., central computer system, regulatory framework) to facilitate the gaming industry in Pennsylvania. The Loan proceeds were expended before any casino opened for business. All Pennsylvania casinos regardless of opening date (including those yet to commence operations) benefit or will benefit from the infrastructure and systems established with the Loan. As such, the Loan repayment should be assessed based on each casino's GTR for the prior fiscal year. Allocating the Loan repayment based upon each casino's cumulative GTR since opening would penalize those casinos that opened early. Some will argue that the casinos that opened earlier should pay a larger share of the loan repayment since the early-opened casinos benefltted from the infrastructure and systems established with the Loan for a longer period of time. This argument fails to take into consideration the fact that the early-opened casinos also commenced paying the Section 1401 assessment for regulatory costs of the three agencies (and payment of gaming taxes) for a significantly longer period of time.

It is also critical for the Board to provide a mechanism to insure that the two slot machine licensees (one awarded and the other yet to be awarded) that have yet to commence operations will be responsible for their fair share of the Loan repayment. We certainly recognize that the Loan will have been fully repaid prior to the remaining two licensees commencing operations, but as discussed above, they will ultimately benefit from the infrastructure and systems established with the Loan and should pay their fair

{00073160}

312 Woodland Road• PO Box 700 •Mt.Pocono, PA 18344 570,243,4800 • www.mountairycasino.com

share. Failure to do so would result in a windfall to these two licensees at the expense of the currently operating casinos.

With respect to the frequency of the Loan repayment, Mount Airy submits that due to the fact no casino could have budgeted for the Loan repayment in calendar year 2018 and HB271 imposes significant new financial obligations on casinos, the Loan repayment should be structured with one-third ($12,033,333.00) due on or before June 30, 2018 (allocated based on each casino's FY 2016-2017 GTR) and two-thirds ($24,066,667.00) on or before June 30, 2019 (allocated based on FY 2017-2018 GTR).

Thank you for your consideration.

Very truly yours,

John Culetsu

cc: Michael D. Sklar (via email)

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