Video Lottery Terminals: A Bad Choice for School Funding A Catalyst for Statewide Casinos
Not one of the economists or expert witnesses to the Select Committee on Public School Finance recommended the addition of Video Lottery Terminals as a desirable source of revenue for public school funding. Using the six criteria for evaluating reform options: efficiency, equity, simplicity, cyclical stability, growth stability, and deductibility* VLT Slots fail the test as a desirable source of revenue. * Dr. George Zodrow, James A Baker Institute for Public Policy, Rice University, An Economic Evaluation of Alternative Sources of Tax Revenue for the State of Texas. Testimony to the Select Committee on Public School Finance, March 10,2004.
I. Classification and definition of video lottery terminals VLT SLOT “Racino Model” A. What are Video Lottery Terminals and Racinos? • A Video Lottery Terminal or VLT is a high-speed slot machine. Video Lottery Terminals are called VLT Slots; they are just like other slots except that they are connected to a central computer system for better tracking and joining jackpot. Just like a slot machine, there is a mechanism that randomly chooses when a player wins or losses. It looks like an arcade game or Las Vegas slot with flashy lights and (usually) a comfortable chair that allows the user to stay at the machine for long periods of time to pump money into it. • Video Lottery Terminals, VLT Slots are NOT used to play current Texas Lotto or lottery games. There are no Video Lottery Terminals in Texas; they are illegal. Advocates of VLT Slots would like to place them in places where Texans have all ready approved some forms of gambling (horse and dog racing), making it look like a simple expansion of current forms of gambling. • VLT Slots are prohibited by the Texas Constitution. Placing 18,000 VLT Slot machines at racetracks creates a new class of gambling prohibited by the state constitution. VLT Slots at the tracks are NOT a part of the Lottery authorized by Texas voters in 1991. Racinos look much like Las Vegas casinos with loud, bright slot machines and all the tricks used to induce long periods of play. The legal definition of a VLT in Texas is: "Video lottery machine" or "machine" means any electronic video game machine that, upon insertion of cash, is available to play or simulate the play of a video game, including video poker, keno, and blackjack, using a video display and microprocessors in which the player may receive free games or credits that can be redeemed for cash, coins, or tokens, or that directly dispenses cash, coins, or tokens. • RACINO = Casino at the track. When VLT Slots are placed in racetrack settings, (usually 1000-5000 machines per track) they are called “Racinos”.
Christian Life Commission 1 [email protected] Baptist General Convention of Texas Current efforts to introduce VLT Slots propose their placement in all Texas dog and horse racetracks, current estimates are based on 18,000 machines at 10 tracks. Racing becomes an afterthought at such facilities. Churchill Downs (Kentucky Derby track) and other successful racetracks do not have VLT Slots.
B. The State’s Ban on Slot Machines Includes VLTs • Video lottery terminals are defined and considered illegal in the state of Texas under the following code: § 466.024. PROHIBITED GAMES. (b)The (lottery) commission shall adopt rules prohibiting the operation of any game using a video lottery machine or machine. (c)In this section: (2)"Video lottery machine" or "machine" means any electronic video game machine that, upon insertion of cash, is available to play or simulate the play of a video game, including video poker, keno, and blackjack, using a video display and microprocessors in which the player may receive free games or credits that can be redeemed for cash, coins, or tokens, or that directly dispenses cash, coins, or tokens.
C. The Texas Constitution Limits Gambling • The Constitution of the state of Texas allows for very limited gambling in the state. Article 3, section 47 titled Lotteries and Gift Enterprises; Bingo Games, allows for gambling in only a very few charitable situations such as church bingo and charity raffles. The only exception is the amendment made in 1991 to allow for the lottery and it states: “(e) The Legislature by general law may authorize the State to operate lotteries and may authorize the State to enter into a contract with one or more legal entities that will operate lotteries on behalf of the State. (Subsec. (a) amended and (b) and (c) added Nov. 4, 1980; Subsec. (a) amended and (d) added Nov. 7, 1989; Subsec. (a) amended and (e) added Nov. 5, 1991.)” VLTs are not included as part of the lottery. VLT Classification VLT slots are Class 3 Gaming because they are not class 1 or 2. (AG’s office - Chapter 29 IGRA section 2703). • Class 1 - Social games for prizes of minimal value or traditional forms of Indian gaming engaged in by individuals as a part of, or in connection with, tribal ceremonies or celebrations. • Class 2 – The game of chance commonly known as “Bingo” for prizes, card games explicitly authorized by the laws of the state, does not include any banking card games (baccarat, Black Jack). Does not include electronic or electromechanical facsimiles of any game of chance or slot machines of any kind. • Class 3 - All forms that are not class 1 gaming or class 2 gaming.
Christian Life Commission 2 [email protected] Baptist General Convention of Texas D. Texas Attorney General: VLTs are NOT a part of “Lottery” approved by voters. • In April of 2003 in light of much discussion in the state legislature concerning VLTs, Rep. Frank Corte requested State Attorney General Greg Abbott to issue an opinion regarding the legal issues that would be involved in such an expansion of gambling. Specifically Rep. Corte asked weather a repeal of the current statutory prohibition of VLTs would require a voter referendum and an amendment to the Texas Constitution. • In his opinion Attorney General Abbott acknowledged once again that VLTs are the equivalent of slot machines, (are class 3 gambling), and would require a constitutional referendum. Mr. Abbott cited an earlier opinion of state A.G. Dan Morales concerning the definition of lottery and slot machines. “Moreover, Attorney General Opinion DM-302 (1994), issued less than three years after the adoption of article III, section 47(e), is a contemporaneous administrative construction of that amendment which concludes that voters in 1991 approved a narrow construction of the term "lottery" that cannot be read to authorize the state to operate slot machines. On the basis of all these factors, we conclude that article III, section 47(e) of the Texas Constitution does not permit the legislature to authorize the state to operate video lottery terminals.” (Attorney General Gregg Abbott, Opinion No. GA-0103 “Re: Whether the legislature may authorize the state to operate video lottery terminals”) Slot machines even if run by the lottery commission are not authorized by the state Constitution.
E. VLTs: Addiction 3 Times Faster than Other Gambling In the Journal of Gaming Studies (co-funded by gaming corporations and the National Counsel of Problem Gaming) research studies conclude that the onset of PG (pathological gambling) occurred three times more rapidly with machine gamblers than with traditional gamblers. • Only one year of play to create pathological addiction. The speed of pathological addiction (the worst form of gambling addiction) was defined as the time (in years) elapsed between the age of regular involvement in the primary form of gambling and the age at which Diagnostic Statistical Manual for mental disorders criteria were first met. Machine (VLT) gamblers became addicted at the worst levels in 1.08 years vs. 3.58 years for other gamblers. • Machine gambling and other disorders. Findings also underscore that alcoholism, depression ad other problems are not necessary prerequisites for (VLT slot) machine addiction. “The results of the current study suggest that intrapersonal variables such as gender and co-morbid disorders do not generally affect the speed with which people develop PG (pathological gambling). Rather, the social, environmental, and stimulus features of mechanized gambling are implicated” (p. 31). • Why do VLTs addict players so fast? “Different forms of gambling vary importantly in terms of stimuli and features that contribute to the experience of the players. For example, many slots players describe the machines as reassuringly hypnotic. The visual stimuli, the repetitive pattern of betting and
Christian Life Commission 3 [email protected] Baptist General Convention of Texas outcome, and the chance to withdraw into one’s own world are features that may contribute to this perception. Machines are the most continuous medium of gambling. • Quick play = Big loses. Bets can be made and decided in a matter of seconds, with virtually no delay before the pattern is repeated. A nickel slot can take $4.50 per second or $54 per minute. Machines are non-threatening and user friendly to the uninitiated, thus they may offer an unparalleled ‘gateway’ activity to gambling” (p. 32). (Breen, R. and Zimmerman, M. (2002). Rapid onset of pathological gambling in machine gamblers. Journal of Gambling Studies, 18 (1), 31-43.) • VLT near-wins prolong gambling. “Players in an experimental condition were exposed to 27% near wins in a series of continuous losses, whereas players in a control group were exposed to none. Participants played as a long as they wished, and received real money for their wins. The results showed that players in the near win condition played 33% more games than did the control group. The results of this study suggest that near wins can be added to the list of factors that may motivate people to gamble despite the probability of monetary loss” (p. 433). • “Further, the near win effect underscores gamblers’ basic failure to understand the random nature of games of chance: the near win is perceived as a sign that a real win is imminent, when in reality the near win is a random event, unrelated to the gambler’s skill or their actual chances of winning” (p. 438). (Cote, D., Caron, A., Aubert, J., Desrochers, V., and Ladouceur, R. (2003). Near wins prolong gambling on a video lottery terminal. Journal of Gambling Studies, 19(4), 433 – 438.)
II. VLTs Open the Door to Large Scale Casinos
A. VLTs Allow Native-American, Commercial Casinos • State Gambling = Allowable Indian Gambling. As long as the State of Texas prohibits class 3 gaming (VLT Slots and casinos), Indian tribe casinos (for two of Texas 3 recognized tribes) and commercial casinos are prohibited as well. • Texas State Comptroller, Carol Keeton Strayhorn, who is an outspoken proponent of VLTs, acknowledges the problem that any state-approved expansion of gambling creates. “Approving video lottery operations in Texas racetracks will almost certainly bring up the issue of gaming operations by our Native American tribes. The tribes are free to carry on any gaming activities that are approved by the state. We need to approach the tribes respectfully, as partners, or we risk losing them entirely” (Texas Comptroller Carol Keeton Strayhorn “New Economic Engine” March 2004.) Mrs. Strayhorn, however, does not elaborate as to what type of partnership she seeks or to the final effect this would have on the reservations or other land owned by the tribes throughout the state. • Calling VLT Slots “limited gambling” is just marketing. Regardless of the state Legislature’s intent, or their effort to include limiting language in the
Christian Life Commission 4 [email protected] Baptist General Convention of Texas wording of a bill allowing for VLT Slots, a court is likely to rely on statutory language and past case precedent to rule in favor of Indian casinos. • The Federal Restoration Act. The Federal Restoration Act controls the relationship between the state of Texas and the Native-American tribes. It says each tribe and their limits of sovereignty are established by agreements between governments and tribes. Regarding gaming: “All gaming activities which are prohibited by the laws of the State of Texas are hereby prohibited on the reservation and on lands of the tribe. Any violation of the prohibition provided in this subsection shall be subject to the same civil and criminal penalties that are provided by the laws of the State of Texas. The provisions of this subsection are enacted in accordance with the tribe’s request in Tribal Resolution No. T. C. -02-86 which was approved and certified on March 12, 1986. (United States Code Title 25 – Indians; Chapter 14, Subchapter LXXVIII (a) Sec 1300g-6. Gaming Activities.)
B. Casino Growth in Other States Through Aboriginal Land Claims • Aboriginal Land claim suits are common - In many other states, including Connecticut, New York, Wisconsin, Minnesota, Michigan, California, Alabama and elsewhere, tribes have won large land claim suits which attempt to redress the immoral and illegal taking of their lands by Anglo settlers. Often the damages to be awarded the tribes would be nearly impossible to enforce since it would involve the taking of land owned by thousands of citizens. In many situations the land includes major cities or towns, hospitals and universities. • Suits are Settled with Casinos - Instead of enforcing these judgments the states often settle the suits for millions of dollars, smaller land allocations and the state grants the tribes the right to build casinos. It should be disturbing, but perhaps not surprising then that casino builders and owners are often the ones that pay the tribe’s legal fees to enable them to bring such land claim suits. • “With nearly a third of the 554 federally recognized tribes running some sort of gambling operation -- and making $ 10 billion a year in the process -- Indians have become major contributors to state and national political campaigns and have tipped the balance of power in many of their disputes over gaining casino rights.” (The Washington Post February 13, 2001 “Tribal Land Claim Meets Resistance in Illinois; Miamis' Suit Viewed as Tactic for Casino Accord” by William Claiborne) • Tribal casino without benefit of state legislative action - December 2003 the Bureau of Indian Affairs granted a land claim for a casino to a tribe in Louisiana without any legislative authorization or approval. (NCALG) • California – Proposition 1A 2000 – changed the constitution to allow tribes to operate casinos on reservations. The idea, in theory was that a modest gambling business would allow Indians to generate sufficient funds to
Christian Life Commission 5 [email protected] Baptist General Convention of Texas revitalize themselves. California now has 46 casinos, 60,000 slot machines (350,000 slots predicted for the next few years). • Commercial gambling interest in California sued for more casinos under the Equal Protection Clause of the 14th amendment. State is obliged to shut down tribal casinos or allow commercial competition. District court ruled in favor of tribes. Case is on appeal and expected to be heard by the US Supreme Court. (San Francisco Chronicle, July 31, 2002 Greed Tars Indian Casinos, by David Lazarus)
C. Texas: Tribal Right to Aboriginal Land Affirmed by Federal Court • In 2002 the Alabama-Coushatta tribe of East Texas won a claim in U.S Court of Federal Claims that recommended Congress award the tribe $270.6 million. The award is based on the revenue the state of Texas gained from oil and natural gas production, timber harvesting, trespass and the use of other natural resources. • The court concluded that the U.S. government is liable because it allowed the state of Texas to profit from the tribal lands and natural resources during its settlement of the area. This breached the duty the federal government owes to the tribe as guardian and protector of their land and interests. • At this point the federal government has not allocated the funds to pay off this outstanding judgment. • Most significantly the court also ruled that the tribe still holds aboriginal title to 5.5 million acres in East Texas. • This means that the tribe could potentially sue the state for compensation for the use of the lands to which they still hold title. • As noted above, tribes in other states have used similar suits to gain casino licenses in exchange for the relinquishment of their title claims. While the Alabama-Coushatta have not said what they would expect to receive from a relinquishment of title, they have had a casino in the past and are fighting hard to reopen it.
III. Social Costs of VLT Slots
A. The Cost of Addiction for Texas The serious costs of gambling will impact Texas counties. According to the National Gambling Impact Study Commission (1999) and 7 major studies 1994- 2000: 1% to 2%, of the population will suffer pathological gambling addiction if gambling expands. Serious costs of $3 (for every $1 in benefits) will fall on taxpayers and families. This is not what the gambling industry wants to advertise. Conservatively calculated at 1%, problem and pathological gamblers in Texas will create BIG costs because of addiction, bankruptcy, insurance fraud and crime.
Christian Life Commission 6 [email protected] Baptist General Convention of Texas Average Cost to Cost Per Average Cost to a Average Cost to a County - Pathological County - a County - Population Gambler per Population Under Population Over 100,000-500,000 year 100,000 in Texas 500,000 in Texas in Texas Addiction costs (1) $9,272 $9,272,000 $23,180,000 $46,360,000 Bankruptcy costs (1) $316 $316,000 $790,000 $1,580,000 Crime costs (1) $4,000 $4,000,000 $10,000,000 $20,000,000 Insurance fraud (2) $3,700 $3,700,000 $9,250,000 $18,500,000 1 Earl L. Grinols and David B. Mustard 2001. Business Profitability versus Social Profitability: Evaluating Industries with Externalities, The Case of Casinos; Managerial and Decision Economics, 22 pg. 143-162. 2 Henry R. Lesieur & Kenneth Puig, Insurance problems and pathological gambling, 3 J. Gambling Behavior 123, 125-127 (1987).
• Problem and Pathological Gambling in Local Areas. Studies show that higher rates of addiction & social costs of all types related to addiction happen in a radius of 50 miles of development with increased intensity. • Addiction is not incidental; it is essential to the business The gambling industry must have addicts; it depends on the revenue of addicts.
Louisiana Legislature, Study of Gambling for the Gaming Control Board (’98) : 30% of all Louisiana gambling revenue comes from addiction.
Riverboat Casino money 29.9% from addicted gamblers Indian Casino money 42.3% from addicted gamblers Video Poker money 27.1% from addicted gamblers Lottery money 19.7% from addicted gamblers
• Youth and Underage Gambling. Studies in Massachusetts, Minnesota, and Nova Scotia show a “high prevalence of problem and pathological gambling among youth, estimated to be two to three times higher than in the general population” (p. 240). • Gambling and Family Violence. “Problem gambling professionals (see) that family violence and other dysfunctions are potential consequences of the full range of disordered gambling, and clinical interventions for family members are being collaborated (p. 242).
B. The Cost of Crime • Problem gamblers impose costs on the rest of society: crime related apprehension, adjudication, incarceration, social services cost for themselves and their families. Lost productivity is another social cost, as well as increased suicide, increased car accidents, increased incidence of child abuse. • Expanding gambling nationwide would be more costly than an additional hurricane Andrew every year in perpetuity - $32 billion in damage. Or it would be the equivalent of an additional 1990-91 recession roughly every decade. (Grinols and Omorov, 1995, as quoted in NCALG.org).
Christian Life Commission 7 [email protected] Baptist General Convention of Texas • Studies show that dysfunctional gamblers use paychecks, savings, and borrowings from friends, relatives, and loan sharks to support their gambling. Many had work-related problems or had been fired from their jobs. Many engaged in illegal acts, such as embezzlement, forgery, filing false income tax returns, and insurance fraud (Cabot).
C. The Cost of Cannibalizing the Consumer Economy • While supporters of casinos and other gambling ventures often point to significant job creation as support for legalized gambling, a closer examination of these studies reveals that the job creation projections are not as optimistic as stated. • Overestimating is common - Claims of dramatically increased economic activity from casinos must be taken with a grain of salt. Studies which fail to account for cannibalized dollars or that rely on significant support from gamblers outside of the community overestimate the potential increase in economic activity. • $250 lost to community businesses, for every $1000 in gambling revenue - Projections of significant job creation often fail to consider the presence of cannibalized dollars—economic activity that would have existed in other sectors—while simultaneously overestimating the level of outside spending that will occur. Realistic economic development projections must consider the net impact on employment and economic activity, not simply the jobs and revenues created by the casino. For example, if a casino moves into a locality and creates 100 jobs, but several local restaurants are forced out of business destroying 100 jobs, the casino did not actually improve the economic well- being of the area. • Positive economic benefit depends on visitors - As USA Today claimed, “you can’t endlessly suck money from the pockets of local gamblers, send 20 percent or more to out-of-state operators, and not disrupt to local economy.” A casino that cannibalizes spending from other local industries will not increase economic activity. While casinos are able to generate some net economic activity by recapturing dollars that are currently being spent in other localities, the major increase in economic activity must come from spending by individuals outside of the community. One recent study found that, depending on the percentage of profits reinvested in the community, a casino must receive anywhere from 49 to 77 percent of its revenue from gamblers outside of the region in order to increase economic activity. • In reality, many casinos fail to even approach the level of outside gambling needed for positive economic activity. In Council Bluffs, NE 68% of gamblers were from the Omaha Metropolitan Statistical Area. In Minnesota, only 6.78% of the $590 million in gambling losses came from out of state gamblers. In addition, 80% of the revenues from the state Indian casinos came from state residents. In Illinois, surveys revealed 80% of gamblers living with 35 miles of the casino. • In reality, many casinos fail to even approach the level of outside gambling needed for positive economic activity. While casinos often claim
Christian Life Commission 8 [email protected] Baptist General Convention of Texas they will be an attraction to tourists, one Chicago area reporter offered a better description of reality: “Hopes for a tourism boom run counter to what industry experts have learned in recent years: gamblers stay close to home if given the chance.”
D. Costs to Vulnerable Populations • 66 to 80 per cent of gambling revenues come from just 10 percent of the population that gamble most heavily. (Grinols) If legislators count themselves in the 90 percent who are not problem gamblers, then aren’t they targeting the weakest members of the population? Their actions become detrimental to the social and economic foundations of Texas (NCALG). • The Poor - Those without disposable income may use their money to gamble instead of buying essential goods and services, such as health care and food, thus lowering their standard of living. Tax benefits to the state from gambling revenues may be insufficient even to remedy the decline in the standard of living (Cabot). “Lower income households spend proportionately more than do higher income households” ( Korn, Gibbons, Azmeir, Framing public policy towards a public health paradigm for gambling. Journal of Gambling Studies, 19:2 p. 241). • The Kids - The fastest growing addiction among teenagers and college-age young people is problem gambling. The rate at which young people become problem gamblers is about twice that of adults • The Elderly - “Although seniors generally have been considered low risk- takers, concern has been expressed about their vulnerability to gambling problems springing from fixed incomes, social isolation and declining health” (p. 241). • Casinos Induce Elderly to Gamble. New cards that casinos encourage customers to use when gambling use personal information to track playing habits and encourage more gambling. A recent book titled, Jackpot!: Harrah’s Winning Secrets for Customer Loyalty, contained the following suggestion about how to use Pavlovian marketing:. “The fact that the player is 60 years old, female, plays slots, and lives in an affluent Memphis suburb that is near Tunica now suggests to us that she’s a good customer, but we just haven’t seen it yet. We’ll measure how fast she responds and how much she plays. What we did with this woman, we have the capacity to do across a 25-million person data base and have it executed in 26 locations by modestly trained people. We have a lot of transaction data on our customer. We know how often they come, what they like to play, if they stay in our hotel, and so on. We take a look at their observed behavior, and our group of analysts builds models to show their predicted behavior. We look to see if there’s a gap between how many times a person comes here and the share of his wallet we receive now, versus what our models say is possible. Using this segmentation strategy, we bucket people into groups and see who comes perhaps twice a year but who should come as many as 20 times a year. Within the traffic our casinos generate, we isolate these groups of customers and send them customized messages. This is Pavlovian
Christian Life Commission 9 [email protected] Baptist General Convention of Texas marketing because we give them carrots such as a $20 food offer or a $20 coin offer to come.”
[Robert L. Shook, Jackpot!: Harrah’s Winning Secrets for Customer Loyalty, quoting Gary Loveman, CEO, Harrah’s and David Norton, Marketing Vice President, Harrah’s (New Jersey: John Wiley & Sons, 2002), p.235-236]
People are being induced to gamble. Is this a practice that the State of Texas should be helping to promote?
IV. Gambling: A Moral Dilemma for Legislators
A. Legislative Responsibility in Amending the Texas Constitution • It is the Legislature’s duty to protect the Texas Constitution. The Texas Constitution states that in order for a proposition or amendment to make it on a ballot, it must be approved by two-thirds of each house of the legislature. This process does not simply pass the responsibility of protecting the constitution on to the people of Texas. • We are not California! where a petition can force a referendum. Any issue on the Constitutional ballot is called a PRO-position because 2/3 majority of the representationally elected legislators have voted FOR the measure. • “Let the people decide. Have a statewide vote.” While it sounds very democratic, Texas Legislators have an independent responsibility to exercise their own judgment as to whether or not a proposed amendment would be good for the state. That responsibility is owed both to the constitution and the people, who look to the legislature to consider the various proposals introduced every year, and to present for voter consideration only those that in its judgment, make sense. • A Vote to put gambling on a constitutional ballot is a vote FOR gambling. It is not a neutral vote.
B. Avoid Ethical Schizophrenia • “I don’t gamble myself, but…” Texas legislators who argue that gambling is good for the state but not good for their own participation have a dual system of ethics. Legislation for the good of the state should be good for all the population, not aimed at exploiting those who do gamble.
C. Fair Policy • Rational policymaking should be based on cost-benefit analysis, including gambler protection to prevent excessive gambling, to keep crime out of gambling, and to ensure fair and honest games (Cabot). Governments
Christian Life Commission 10 [email protected] Baptist General Convention of Texas should not sanction exploitation of the public. Instead governments should seek to adopt laws that prevent the practice of encouraging people to gamble by limiting advertising, entertainment, junkets, or other activities.
D. Avoid Revenue Schizophrenia • In the case of sin taxes the state wins approval for taxing vices by claiming one of the purposes of the tax is to discourage public participation in such activities. Other examples included cigarette and alcohol taxes. However, if public use of these taxed items were to decline, so would revenue. It is the same with gambling. The difference here is that the state actually promotes the behavior by spending millions of dollars a year on advertising and promotion of the current lottery. This is the equivalent to the state paying for the cigarette and beer advertisements. • Gambling corporations in a contractual relationship with the state to provide a state service (state-run games etc.) should be excluded from lobbying the legislature, just as the state agency they represent is excluded. Otherwise the corporation receives tax money and lobbies the legislature.
E. Republican Party Platform and Gambling • The recent school funding and tax plan proposed advocates an expansion of gambling in Texas, including video lottery terminals. This promotion of gambling runs counter to the Republican party platform. The “Strengthening Families and Promoting a Freer Society” section of the 2002 State Republican Party Platform states:
“Government–Sponsored Gambling – The Party continues to oppose government–sponsored gambling as a means of financing state government. Government–sponsored gambling has had a devastating impact on many Texas families. Moreover, we oppose any further legalization, government facilitation, or financial guarantees relating to any type of gambling including casino, riverboat, slot machine, video keno, eight-liners, and other games of chance. The Party supports the repeal of the state lottery.”
Christian Life Commission 11 [email protected] Baptist General Convention of Texas