PROVIDENCE — A lawyer for the Rhode Island Greyhound Owners Association asked state racing regulators, in a letter hand-delivered on Thursday, for “the opportunity to be heard before the agency renders a decision on whether or not Twin River may suspend greyhound racing at their facility as of August 8.”

In response, the head of the state’s Department of Business Regulation (DBR) issued a preliminary denial, based on the dog owners apparent “lack of standing,” according to the governor’s office. A final decision is expected Friday.

In the letter, lawyer Joseph Cavanagh Jr. argued: “Greyhound racing has a significant impact on the state of Rhode Island and a suspension of racing will have an immediate, direct and adverse effect on Rhode Island workers, small businesses and taxpayers ... As such, we respectfully request that the Association be provided notice and an opportunity to be heard should DBR … consider altering the fixed days upon which greyhound racing is scheduled to take place at Twin River for the balance of 2009.”

The letter is premised on a reported three-page contract between the kennel owners and the owners of the sprawling greyhound track and slot parlor in Lincoln, home to 12 greyhound kennels, an estimated 1,200 dogs and 4,752 video-slots.

To date, however, neither side has been willing to make public the contract, which reportedly commits Twin River’s owners to paying the dog-owners a $10-million annual subsidy, even though their net from the $13,246,233 wagered on dog-racing in 2008 was only $1.7 million. State taxes from the live races were just shy of $1 million.

The kennel owners’ move drew this response from Twin River spokeswoman Patti Doyle: “We took this necessary yet unfortunate step to preserve revenue in the event of a Chapter 11 filing with the U.S. Bankruptcy Court. … We deeply regret the suspension of dog racing at Twin River and more important, we regret the loss of every employee who will be impacted by this action.”

The DBR earlier this week told the track it could not suspend racing on May 31 as originally planned because it would not, at that point, have held the minimum 125 racing dates required under law to keep its license and the video-slots that bring in most of its gambling dollars. In response, Twin River held off on the suspension until Aug. 8.

RIGOA spokeswoman Jennifer Bramley said the loss of live greyhound racing would “impact 225 workers, put a number of small-business owners out of business, leave 1,200 greyhounds in limbo and reduce tax payments to the State of Rhode Island by millions of dollars, thereby directly affecting taxpayers.”

The estimated $7.5 million state revenue loss was based, in large part, on the assumption that video-slot revenues would drop by more than $5.5 million annually if gamblers were not drawn to the former Lincoln Park to see the dog races. Among the other assumptions: $337,500 in lost income taxes from the 225 laid off kennel workers, judges, pari-mutuel clerks, concessionaires and security staff.

Doyle said Twin River had been presented with this loss-projection by the dog owners before, and “I would absolutely question how they arrived at the $5 million lost [video slot] revenue projection — is it their assumption that the loss of customers attending dog racing translates into that much lost revenue at the slot machines? We do not recall any acceptance of that figure.”

kgregg@projo.com