Mayor and Council,
City of Vancouver
453 West 12th Avenue
Vancouver BC V5Y 1V4
Via E-mail

April 7, 2011

Dear Mayor and Council,

Re: Proposed Relocation and Expansion of Edgewater Casino

We, the undersigned, are members or retired members of the VPD, RCMP and other law enforcement agencies operating in BC, Canada, and internationally. We all have decades of experience in law enforcement, and many of us have particular experience or undercover expertise with organized crime, gangs, and money-laundering. Organized crime and gang activity have become deeply entrenched in the Metro Vancouver environment and represent an ongoing threat to public safety.

We urge this Council not to approve the proposed expansion and relocation of the Edgewater Casino. Casinos and racetracks are well known for their vulnerability to the activities of gangs and organized crime–money-laundering, loan-sharking, extortion, and prostitution, as well as for the vulnerability to public corruption which they engender.

That organized criminals and gang members frequent BC casinos, and easily use them to launder money, or use them as sites for the operation of loan-sharking and prostitution, is well known. Policing in casinos and racetracks requires a robust commitment to real enforcement of the law–a commitment that is plainly lacking at the present time.

Further, we are very concerned about the impact of increased gambling on our addict population, or those at risk of entering it. We note the 2009 report of the B.C. Medical Association, Stepping Forward, which found that the incidence of severe gambling addiction has more than doubled between 2002-2009, and that BC now has nearly as many severe gambling addicts as it does drug addicts. Additionally, the Centre for Addiction and Mental Health has recently released a study showing that 29,000 Ontario teens in grades 7-12 now show signs of problem gambling.

It is no coincidence that these youths are also significantly more likely than their peers to engage in gang violence, carry a handgun, and deal drugs other than cannabis. Tragically, they are also 18 times more likely than their peers to have attempted suicide in the past year.

Locating a major casino in a major regional sporting complex sends a poor message to our youth.

Addiction is a blight on society. It has a close and mutually reinforcing relationship with crime. It promotes additional offenses such as property crimes and drug-dealing, as victims seek the money to feed their habits–whatever those may be. There is no way to measure the social cost of this suffering on victims and their families, but the health, policing, criminal justice, social services and corrections systems as well as charitable service agencies all bear the brunt of the increased pressures brought about by this public problem.

Securing new sources of government funds from addicts to pay for their increased demand on government services is not wise public policy.

Without significant changes in the policing protocol, and the adoption of rigorous crime control standards for casinos such as those employed by the Ontario Provincial Police, we are in no position to deal with the increased criminal activity that will necessarily attend the development of a massive casino on the scale proposed here.

As citizens and public servants, we owe a duty of care to society’s weakest and most vulnerable, to our youth and seniors, and to the public at large. As police officers, we have seen the ravages of addiction and of gang and organized crime first-hand. The connection is closer than most members of the public may imagine.

We urge Vancouver City Council to vote against the expansion and relocation of the Edgewater Casino.

Yours truly,

Assistant Commissioner Earl Moulton – RCMP Commanding Officer Saskatchewan
(Ret’d)  Chair of Vision Quest Recovery Society (Addiction recovery services, BC)
Deputy Chief Constable Peter Ditchfield, Organized Crime Agency of BC (Ret’d)
Detective Ian Pope, Organized Crime Agency of B.C., formerly VPD, (Ret’d)
Sergeant Bob Cooper, VPD Asian Organized Crime Section, (Ret’d)
Sergeant Ivan Chu, New Westminster Police Service (Ret’d)
Superintendent GlennWoods, Officer in Charge of Behavioural Sciences, RCMP (Ret’d)
Staff Sergeant Otto Bertagnolli, RCMP Drug Section (Ret’d)
Staff Sergeant Scot Filer, RCMP Major Crime Section (Ret’d)
Staff Sergeant Peter Montague, RCMP Commercial Crime Section (Ret’d)
Corporal Howard Parks, RCMP Money Laundering Expert (Ret’d)
Corporal Chris Mathers, RCMP Money Laundering Expert (Ret’d)
Sergeant Pat Powell, RCMP Threat Assessment Expert (Ret’d)
Inspector Keith Davidson, RCMP Major Crime Section (Ret’d)
Staff Sergeant Bob Hartl, RCMP Security Engineering Expert (Ret’d)
Dr Teal Maedel, RCMP Operational Psychologist (Major Crime Section)
Staff Sergeant Robert Stenhouse, RCMP Drug Section (Ret’d)
Staff Sergeant Sid Slater, RCMP Major Crime Section (Ret’d)
Staff Sergeant Tibi Roman, RCMP Border Integrity (serving)

ABOUT THE PROJECT

Connection with B.C. Place Stadium: direct link to stadium attendees, with a separated walkway directly to the casino from corporate suites.

Size of gambling space in the expanded Edgewater Casino: 2 football fields

Size of this casino compared to all casinos in western Canada: #1

Number of electronic slot machines in current Edgewater Casino: 520

Number of electronic slot machines in expanded Edgewater Casino: 1,500

Percentage of electronic slot revenues estimate to come from problem gamblers: 35%

Number of studies done in B.C. to determine the social, crime and financial costs of problem gamblers in this province: none

Cost of policing, addictions, suicides, fraud, courts related to problem gamblers using this casino: unknown

Estimated annual cost of a problem gambler from missed work, fraud, bankruptcies, receiverships, embezzlements: $13,200

ABOUT THE PROCESS

Date that B.C. Lottery Corporation chair Richard Turner buys shares in Paragon’s Alberta business: 2003

Date that Turner discloses that interest: 2005

Date that Turner resigns from BCLC board: late 2005

Date that Paragon Gaming purchases Edgewater Casino out of bankruptcy and installs Turner on the board of Paragon: summer 2006

Amount of donation by Richard Turner to B.C. Liberals while Paragon’s bid is awaiting a decision by Pavco in 2009: $50,000

Time between Pavco’s invitation to two short-listed companies responding to a request for expressions of interest in this $450-million project and its announcement of Paragon as the preferred proponent: less than 11 weeks

Normal time for big government projects to determine the best proponent, according to Partnerships B.C.: 12-16 months.

Number of minutes spent debating Edgewater’s expanded casino by Vancouver City Council: 0

ABOUT BROKEN PROMISES TO THE CITY OF VANCOUVER

Projected return of expanded Edgewater casino to City of Vancouver: $10 million in new revenue from gambling

Projected revenue to City of Vancouver from Edgewater’s original casino in 2004: $10-12-million in new revenues

Actual annual return of Edgewater Casino to City of Vancouver over the past two years: $6.3 million

Promise to arts groups and charities in 2004: increased funding
What charities got in 2010: 14% less than they got in 1995
What BC Lottery Corporation got in 2010: about three times as much revenue as 1995.

Promise to bingo players and their funding recipients in 2004: New Planet Bingo hall at Edgewater
Status of promise in 2011: Never delivered

ABOUT PARAGON GAMING

Number of slot machines in Paragon’s only Las Vegas operation, a sports bar: 15

Source of Paragon’s financing for Vancouver: unknown

Number of jobs promised by Paragon in 2010 bid for a casino in Missouri: 573

Number of jobs calculated by the Missouri Department of Economic Development for the same project: 280

Estimated annual revenue by Paragon in Missouri bid: $103.4 million

Estimated real new annual revenue calculated by the Missouri independent review of the same project: $21.7 million

Status of Paragon bids to build casinos in Sugar Creek, Missouri; Moncton, New Brunswick; Oxnard, California; and Ventura County, California: all failed

Answer of Unite Here, a union of 100,000 gaming workers across North America, to the question: “Is Paragon really the right company to take on this project?”: “no”

Disturbing event that occurred at Paragon’s Cree River Casino outside Edmonton in August 2010: customer murdered after a fight in a lounge that spilled outside.

ABOUT CRIME AND GAMBLING IN B.C.

The two best places to meet gangsters in B.C., according to Fred Pinnock, former Commander, Integrated Illegal Gambling Enforcement Team: in jails and in casinos

Hours of shifts of loan sharks at River Rock Casino revealed in Oct. 2006 murder trial of loan shark Lily Li: 24/7

Percentage increase in gambling-related crime reported by Richmond RCMP after River Rock’s establishment: 400%

Percentage of money-laundering and terrorism financing cases discovered in 2008-9 that took place in casinos, according to FINTRAC: 20%

Date that RCMP’s Integrated Illegal Gaming Enforcement Team issued a report to the provincial government warning of “extreme vulnerability” of casino industry to organized crime–money laundering, infiltration, loan sharking: January, 2009

Date that B.C.’s Integrated Illegal Gambling Enforcement Team was disbanded by the provincial government: February, 2009

Date that BC Lottery Corporation was fined $670,000 by FINTRAC for repeated failure to monitor suspicious transactions, the first fine of its kind in Canada: Summer, 2010

Number of dollars involved in suspicious cash transactions at 2 casinos in Metro Vancouver, including $460k in 20’s in plastic bags, and a suitcase with $1.2 million in casino chips, revealed by CBC in 2010: $8 million.

Reaction of Insp. Baxter, head of RCMP Proceeds of Crime Unit, to these transactions: “suspicious”

Reaction to these transactions of Rich Coleman, Minister of Public Safety and Solicitor-General, also in charge of raising revenues through gambling in B.C.: “not suspicious”

Number of sentences in Vancouver city staff’s 55-page report on the B.C. Place rezoning mentioning organized crime or money-laundering: 1

ABOUT THE ECONOMIC CASE

Amount listed in Deloitte report on this project as an annual capital payback from B.C. Lottery Corporation to Paragon: $16.9 million

Estimated increase in business over Edgewater’s current revenues: 180%

Percentage of North American casino customers who live within 45 minutes of the casino: 90%

Paragon’s estimate of the number of gamblers expected to come to Vancouver every day exclusively to gamble in the new casino and stay in its 648 new hotel rooms: 548.

Feb. 2011 comment by veteran hotel broker Angus Wilkinson on the demand for new hotels needed in the city: “This city doesn’t need another single hotel room.”

Amount that would have to be charged per night for a new hotel to survive financially in Vancouver, according to Wilkinson: $400/night

Average hotel room rate in Vancouver in 2010: $166/night

The current Edgewater Casino is quietly slated for  a location move and then a massive expansion in our downtown core, right near the BC Place Stadium. This could happen within a matter of weeks. It will put the casino adjacent to all of the high-end dense living of False Creek and Yaletown, not to mention adjacent to the Downtown Eastside, already plagued by crime and addictions.

Massive casinos, which are generally not found in the downtown cores of other North American cities, other than Vegas, attract endless undesirable social problems: crime, loan sharks, addiction. They are not socially palatable. Nor will this mega-casino complex be architecturally palatable – it will be designed and built by Vegas. It’s not even going out to architectural competition – its design has already been proposed and it’s hideous. We have already had an ugly, expensive and impractical stadium roof foisted upon us by the BC Liberals government; now we will be subjected to this massive gambling expansion unless we speak up. The province has bullied Vancouver enough. City Hall, start standing up to the bullies! What cards are they holding that you fold so easily?

Write to the mayor and city council! Tell them how you feel about this scheme which is very quickly and very quietly being pushed through City Hall by the BC provincial government.

Also note: gambling expansion has been pushed throughout BC with the excuse that it pays for our crucial non-profit and charity sectors. Despite laws legislating this, it has never been done. Money from the casinos is being used to fill in the gap left by the government’s own economic policies.

Please be heard!

Don’t let them gamble Vancouver’s liveability away.

Thank you.