future, the Shoshone-Bannock Gaming would certainly not want to close its doors
to class Il gaming devices, we would allow the opportunity to explore the
opportunity if the economic condition are certain to conduct class Il gaming on
the Fort Hall Reservation. As of now, there is no attraction to class Il gaming here

at the Shoshone-Bannock Gaming.

If there are any questions, please contact our office 208-237-8774, extension
3025. Thank you for the opportunity to comment on the regulations and how the

standards apply on the Fort Hall Reservation, Idaho.

Sincerely,
qlee
Marvin D. Osborne, Executive Director

Shoshone-Bannock Gaming Commission
Cc: file


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FORT HALL INDIAN RESERVATION Nal GAMING COMMISSION
PHONE: (208) 237-8778 Ext. 3024 NN PO. BOX 306
FAX: (208) 637-6623 REX) FORT HALL, IDAHO 83203

FAX: (208) 637-6622

May 31, 2017

Jonodev Oscelola Chaudhurt, Chairman
National Indian Gaming Commission
1441 L Street NW, Suite 9100
Washington, DC 20005

Subject: NIGC Grandfather Class II Gaming System Sunset Provision

Dear Mr. Chaudhurt:

The Shoshone-Bannock Gaming Commission of Fort Hall, ID submits the
attachment regarding the NIGC Grandfather Class II Gaming System Sunset
Provision of 25 C.F.R. Part 547.

If you have any questions, please feel free to contact our office at (208) 237-8774,
ext. 3015.

Sincerely,

Jabot bag ldbinee

Clinton Plenty wounds, Chairman
Shoshone-Bannock Gaming Commission
File

Attachment

Cc: FHBC


25 C.F.R. Part 547 Grandfathered

Class Il Gaming Systems
May 31, 2017

Thank you Mr. Chairman and Members of the Commission for the opportunity to
make oral and written testimony during the consultation hearing in Portland,
Oregon on May 25, 2017. The Shoshone-Bannock Gaming Commission replies to
25 CFR Part 547 the Grandfathered Class II Gaming System. The National Indian
Gaming Commission seeks comments to the following questions: (1) any
information related to the steps tribes have taken to comply with the
grandfathering provision and any difficulties in implementing those provisions; (2)
what risks, if any, the grandfathered games may pose to a gaming operation or
the gaming public; (3) how those risks may be mitigated by means other than Part
547; and (4) what impacts, if any will the November 10, 2018 deadline have on

your operation?

Whereas the Grandfathered gaming systems of any Class II gaming system
manufactured before November 10, 2008, that is not already certified pursuant to
this sub-section or compliant with paragraph (c) of this section may be made
available for use at any tribal gaming operation providing compliance are

approved.


However, Shoshone-Bannock Gaming cannot submit for an operation system
because it does not have class II gaming devices. Bingo systems are govern by a
contract vendor providing their own server system and equipment. Tracking of
financial records are thru the internal financial system for accountability. The
Shoshone-Bannock Gaming Commission is not in a position to submit the Class II
gaming system software that affects the play of the Class Il games, together with
the signature verification required by §547.8(f) to a testing laboratory recognized
pursuant to paragraph (f) of this section within 120 days after October 22, 2012.
The Shoshone-Bannock Gaming does not have class II gaming devices at any of

the three casinos on the Fort Hall Reservation, Idaho.

No testing laboratory tests have been conducted by Shoshone-Bannock Gaming
and no risk are involved for the submission to the standards established by
§547.8(b), §547.8(f), §547.14, and any additional technical standards adopted by
the Shoshone-Bannock Gaming Commission other than the Tribal Internal Control
System and internal regulatory requirements of the Shoshone-Bannock Gaming

Commission are in place at this time.

The Shoshone-Bannock Gaming Commission do not conduct any class II gaming
system devices and equipment on the Fort Hall Reservation, Idaho. If we have

over looked any criteria that may change our view to class II gaming in the near