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Caroline Lamb informed a recent review that the current responsibility of annually processing over 500 ClubGRANTS applications within a short time frame imposed significant constraints.
Lamb described this task as “practically limiting the authority’s ability to most effectively monitor compliance” across the scheme.
She suggested that the State Revenue chief commissioner’s office would be better equipped to manage what she characterised as a tax rebate programme.
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He emphasised the new system would make burdens less demanding than before, but the new ‘exit plan’ requirement and sharper duty‑of‑care definitions do bring some added complexity.
The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.
All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.
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The conflict stems back to January 2025, when the outgoing Biden administration initially determined that the Vallejo parcel was eligible for gaming.
Interior temporarily rescinded that determination just two months later after newly appointed Secretary Doug Burgum raised concerns over whether the tribe’s historical connection to the land had been thoroughly evaluated.
Scotts Valley filed suit in response. In October 2025, Judge McFadden ruled that Interior had violated the tribe’s due process rights by rescinding the approval without giving prior notice or an opportunity to respond.
