Pennsylvania appears poised to retain its status as home to some of the most player-friendly blackjack rules in the country.

In mid-August, the state’s Gaming Control Board formally proposed that Pennsylvania’s current blackjack rules be made permanent. Those include requirements that naturals be paid at 3-to-2, the dealer stand on soft 17 and all casinos offer late surrender. In addition, the rules specify the option of doubling on any two cards and doubling after a split.

The board’s proposal also would allow double-deck pitch games with the same rules. Currently, all games must be dealt from a shoe; I don’t know of any Pennsylvania casino dealing fewer than six decks.

The Gaming Control Board sets rules for all casinos in the state. Casinos may vary in a few specified areas – the number of resplits, for example, or whether players may resplit Aces – but the broad blackjack rules apply at all casinos and all betting levels.

Rules for all table games, not just blackjack, are up for review. After the Legislature approved the addition of table games in 2010, the Gaming Control Board established temporary rules so games could get started as soon as possible. The temporary rules expire in 2012.

The blackjack rules must pass through a bureaucratic maze before becoming permanent. After the 30-day public comment period ends Sept. 12, the state’s Independent Regulatory Review Commission has time to make comments. The Gaming Control Board responds to all comments before submitting a final version of the regulations. The process could take months.

Last year, when temporary rules were being considered, casino industry representatives unsuccessfully pushed for the options of 6-to-5 payouts and h17. They’re likely to try again, tempting regulators with the siren call of increased tax revenue, which would come from increased player losses.

The Gaming Control Board’s analysis for the Review Commission anticipates those arguments:

"The board believes that the fundamental rules of play in blackjack, including optional surrender and the requirement that dealers stand on a soft 17, achieves a fair and appropriate balance between the revenue generated for the certificate holders, and derivatively to the Commonwealth, and the fairness to patrons," the analysis says.

In their first 12 months of operation, table games, other than poker, generated more than $451 million in revenue at Pennsylvania’s 10 casinos; state and local governments got $81.4 million of that through taxes totaling 16 percent. Unlike Nevada and New Jersey, Pennsylvania does not break down how much revenue each type of game generates. However, blackjack is the most popular casino table game worldwide, so it is responsible for a significant chunk of the Pennsylvania totals.

Players should make sure regulators hear their side:

• Casinos already enjoy an edge in blackjack, even over the relatively few devout basic-strategy players who make the right play every time. Most players make mistakes or choose not to follow basic strategy all the time. The house advantage is 1.2 percent or more with the vast majority of players. Allowing 6-to-5 would more than double that edge. Allowing h17 would increase it further.

• Pennsylvania casinos are doing just fine under the current rules, and the state appears poised to overtake New Jersey as a prime gambling destination.

• Current blackjack rules make Pennsylvania casinos far more attractive to gamblers than those in neighboring jurisdictions, especially New Jersey. Touting the player-friendly rules, not weakening them, is the best way to bring in more money.

• Gaming regulators have a responsibility to casino patrons as well as to casinos. Allowing 6-to-5 and h17 would harm all players regardless of skill level. Increasing the house advantage by changing the rules would be unfair to bettors. Doing it after a year of good rules would smack of bait-and-switch.

• Sooner or later, many players would realize they simply can't win with 6-to-5 and h17. They would play less, or not at all, and the predicted increase in tax revenue would not materialize.

The Gaming Control Board got it right last year by establishing a blackjack game that gives all players, novices and experts alike, a fighting chance. As the board says, the state should keep those rules.

It’s only fair.

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Speak out

BJI readers can write to the Pennsylvania Gaming Control Board to tell them you are in favor of the present blackjack rules. The official public comment period ends Sept. 12. Send email (or mail) comments to:

Susan A. Yocum

Assistant Chief Counsel

Pennsylvania Gaming Control Board

P.O. Box 69060

Harrisburg, PA 69060

Fax: 717-703-2988

E-mail: syocum@state.pa.us

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After I reported on Pennsylvania blackjack conditions last fall, a BJI reader wrote about a novel discard device at Philadelphia’s Parx casino. It had a "well" in the middle of the table that collected discards below table level, so players could not tell how many cards had been used. In addition, the shoes had an opaque cover, so players could not see how many cards remained to be dealt. In July, the reader reported that standard discard trays had replaced the wells. In response to a query, the dealer said the wells were removed because customers did not like them. The shoes still have an opaque cover but the discards are visible, the reader said.