The City of Fayetteville is proposing to build a combined indoor/outdoor aquatic facility at Lewis Fields — a multi-use athletic park along Hamestring Creek — at a cost the city’s own records show could reach $92.2 to $113 million in construction alone. A review of FOIA documents obtained from the city reveals four interlocking problems that together make a compelling case for halting or fundamentally reconsidering this project.

Financial unsustainability. The city’s final feasibility study acknowledges that facilities covering their full operating costs are “rare,” projects 30% of costs will require permanent taxpayer subsidy, and the competition pool alone is projected to run at a $350,000–$400,000 annual deficit. Internal city emails show the city’s own Park Planning Superintendent raised alarms about financial risk in December 2025 — and was asked by his supervisor to stay quiet until administration could “discuss.” The project’s cost estimate also contains $10.8 million in contingencies on top of a geotechnical investigation that has never been completed.

A floodplain-compromised site. Lewis Fields sits in FEMA Zone A, and Hamestring Creek originates within the park itself. The city’s own 2021 drainage engineering study found the area has chronic, unfixable flooding caused by “lack of topographic relief” — a permanent physical characteristic of the land. A city stormwater expert confirmed that development would increase downstream flooding in adjacent low-income neighborhoods. Federal CLOMR (map revision) approval from FEMA will be required and may not be granted. Wilson Park Pool was rejected as a redevelopment site for nearly identical floodplain reasons — yet that logic was not applied when Lewis was selected.

A rigged site-selection process. FOIA records show the city’s own Parks Director and her deputy were privately critical of the consultant’s site analysis, with Director Jumper writing that consultants were “not putting any real effort into site selection.” The two public surveys conducted never mentioned Lewis Fields or Wilson Park as candidate sites, and the second survey was “restricted to focus on proposed concepts.” Lewis was ultimately selected because it avoided land acquisition costs — not because it was the best fit for the community. The Fayetteville School Board was never formally consulted before the site was locked in.

Documented public opposition. A community group, Save Lewis Fields, has organized formal opposition. Resident Helen Ames copied the full City Council in a March 2026 letter raising floodplain risks, wildlife habitat concerns (bat colonies and endangered birds in the tree canopy), and the threat of displacement for residents of the adjacent Washington Plaza public housing complex. The city’s responses to these concerns have been evasive, committing to no specific mitigation plans.

KEY NUMBERS AT A GLANCE: $92.2M–$113M construction cost | $10.8M contingency reserve (untested soils) | 40–45% cost recovery on competition pool | $350K–$400K/yr competition pool subsidy | $2.6M hidden offsite infrastructure | FEMA Zone A — CLOMR required | 5¢/kWh electricity projected vs. 13¢/kWh actual

1. FINANCIAL CONCERNS

1.1 The Official Cost Estimate Is Already $92 Million — and Still Growing

The most recent official cost estimate, contained in an internal memo circulated in January 2026, sets the total project cost at $92,175,349.

“I want to bring to your attention that the estimate includes $10,777,000 in contingencies and escalation.” (Source: Aquatic Center Estimate Breakdown Contingencies and Bond Package Decisions.pdf, p. 1 — Wade Abernathy, Project/Construction Director)

The contingency breakdown reveals structural risks rather than routine prudence:

5% escalation contingency — covers only through mid-2027, but construction runs through September 2028, leaving 16 months of escalation exposure with no financial coverage
4.5% design contingency — acknowledges the design is not yet finalized
5% construction contingency — explicitly assumed to cover only “minor undercut for unsuitable soils,” a caveat that matters because no soil testing has been done

Critically, the geotechnical investigation has not yet been completed: “A geotechnical investigation has not yet been completed on the Lewis [Park] property. Unsuitable soil conditions, groundwater discovery, and rock excavation all have the potential to adversely impact the construction budget.” (Source: Aquatic Center Estimate Breakdown, p. 4)

If significant subsurface problems are found, the entire $10.8M contingency could be consumed before a single water slide is poured. The estimate also explicitly excludes: design fees, furniture/fixtures/equipment, A/V systems, IT systems, and impact fees for police, fire, water, and sewer. (Source: Aquatic Center Estimate Breakdown, p. 1)

1.2 The True Program Cost May Reach $113 Million

A Parks Department internal memo — generated when all planned program elements were costed together — shows a full-facility figure of $112,916,274. Even the reduced scope (removing the competition pool, gymnasium, and meeting rooms) still totals $69,484,212. (Source: Next Steps Aquatics.pdf)

The cost range reflects what the Parks Director herself called unreliable estimating. In a December 2025 email circulated internally, Parks Director Alison Jumper wrote: “The estimate needs a lot of work in my opinion,” and questioned whether unit cost assumptions were realistic. (Source: Next Steps Aquatics.pdf)

1.3 Permanent Taxpayer Subsidy Is Built Into the Plan

“Facilities that can consistently cover all of their operating expenses with revenues are rare. The first true benchmark year of operation does not occur until the third full year.” (Source: FayettevilleAquaticsFeasibilityStudy_FINAL.pdf, p. 34)

The city’s own final feasibility study, commissioned by the Parks Department, explicitly forecasts ongoing taxpayer support. Key admissions from the study:

Cost recovery is projected at approximately 70% — meaning 30% of annual operating costs must be subsidized in perpetuity. (Feasibility Study FINAL, p. 24)
Annual operating costs at comparable facilities run $2.5 million to $3.0 million, with 70% attributed to personnel — a cost category that rises significantly each year. (Feasibility Study FINAL, p. 34)
The study notes that cost recovery has been declining nationally as operating costs rise faster than admission fees.
“Indoor aquatic facilities will likely need ongoing financial support through public investment, sponsorships, and/or private partnerships.” (Feasibility Study FINAL, p. 6)

1.4 The Competition Pool Alone Carries a $400,000 Annual Deficit

A proforma provided by consultant Counsilman-Hunsaker in December 2025 projects the competition pool’s standalone financials. The numbers are stark:

Annual expenses: $675,000–$700,000
Annual revenue: $300,000–$315,000
Cost recovery: 40–45% only
Annual deficit requiring subsidy: $350,000–$400,000

(Source: [External] RE 25304800; Fayetteville Aquatics – Proforma Information.pdf, p. 4)

The same proforma was built using an electricity rate of 5 cents per kWh. When city staff discovered the actual rate was 13 cents per kWh — a 160% error — they requested a revised model. This revision was requested only weeks before key decisions were being made. (Source: [External] RE 25304800; Fayetteville Aquatics – Proforma Information.pdf, p. 3)

1.5 $2.6 Million in Required Offsite Infrastructure Not in the Estimate

An email chain between the city’s Project Director (Wade Abernathy), Public Works Director (Chris Brown), and Parks Director (Alison Jumper) identifies $2,638,219 in required offsite infrastructure that is not included in the $92M estimate:

Required Work	Preliminary Cost
Downstream sanitary sewer improvements	$684,400
Lewis Avenue full reconstruction (1,350 ft)	$1,214,828
Trail connections and pedestrian safety improvements	$739,191
Franchise utility relocation and ROW acquisition	Not yet calculated
TOTAL (partial)	$2,638,219+

(Source: 25304800; Offsite improvement documents.pdf)

Public Works Director Brown confirmed “existing downstream capacity issues… even before our added flows” and called a formal flood study “prudent given the proposed changes within the floodplain/floodway areas.” Abernathy warned that these requirements “differ from what was discussed with Planning a few weeks ago,” and that administration would need to eliminate project elements to absorb these costs. (Source: RE Aquatics – Offsite Analysis.pdf)

1.6 Internal Warning: A Senior Staffer Raised Alarms and Was Told to Stay Quiet

In a December 5, 2025 email chain, Park Planning Superintendent Ted Jack drafted concerns about the project’s financial sustainability — citing national case studies of aquatic facilities that far exceeded their projected subsidies. His supervisor, Parks Director Alison Jumper, stopped him from sending the analysis:

“He Ted, please hold on this. I’ve discussed with Keith this week and Admin is confident about FPS and the competition pool. I’m happy to share more Monday, but I’d prefer you not send anything until after we can discuss.” (Source: From Ted Jack.pdf, p. 1 — Alison Jumper, Parks Director, December 5, 2025)

Jack’s suppressed analysis warned that industry pro formas “often underestimate operational costs by 20–40%, particularly for staffing and utilities,” and cited comparable facility failures:

Port Townsend, WA: Analysis of the William Shore Pool revealed a $1.3M annual subsidy — far exceeding initial projections. (From Ted Jack.pdf, p. 8)
Leavenworth, WA: A $21.6M facility study projected a $650,000 annual subsidy with multiple unfunded contingencies. (From Ted Jack.pdf, p. 8)
General industry finding: “Pro formas often underestimate operational costs by 20–40%, particularly for staffing and utilities.” (From Ted Jack.pdf, p. 8)

Jack further noted: “Over the years I have seen many articles of indoor aquatic facilities facing financial problems. I would expect the indoor family aquatic portion to require less subsidy than the competitive pool only model, but still a significant subsidy.” (From Ted Jack.pdf, p. 2)

2. ENVIRONMENTAL AND LAND USE ISSUES

2.1 The Site Is in a FEMA Floodplain — and Federal Approval Is Required

Lewis Fields is located in a FEMA Zone A floodplain. Hamestring Creek originates within the park. The city’s engineering team has confirmed that any development in this zone will require a Conditional Letter of Map Revision (CLOMR) from FEMA before construction can proceed — a costly, time-consuming federal process with an uncertain outcome.

“The bond item for the Aquatics Center at Lewis Park is partially in a floodplain. Hamestring Creek begins in Lewis Park. Was a hydric study completed. A CLOMR or LOMR may be required.” (Source: RE Aquatics Center.pdf, p. 1 — Lisa Valentine, AGFC Hamestring Creek Trail Stream Team Leader, December 28, 2025)

Internal engineering communications from Crafton Tull (the city’s design consultant) confirm:

The site requires a no-rise certification — i.e., the development must demonstrably not raise flood elevations anywhere upstream or downstream. (Source: RE Lewis Park.pdf)
The planned detention basin may actually widen the floodway, triggering additional federal regulatory requirements. (Source: RE Lewis Park (3).pdf)
Removing the existing concrete channel on-site adds additional hydraulic complexity and cost. (Source: RE Lewis Park.pdf)
The existing Mt. Comfort Road culverts are already at capacity — “limiting flows” even before new development. (Source: RE Lewis Park.pdf)
The city stormwater manager has stated: “Floodplain extends beyond mapped FEMA zones. Increased rainfall intensity elevates risk even in moderate-risk areas.” (Source: Stormwater Verbiage.eml)

2.2 The Site Has Chronic, Inherent Flooding Problems That Cannot Be Engineered Away

The city commissioned a comprehensive drainage analysis of the Upper Hamestring Creek watershed in 2021. That study — prepared by civil engineering firm FTN Associates — documents that the Lewis Fields area has a fundamental, unfixable flooding problem:

“Once the various models were completed, the modeling revealed that no single proposed improvement scenario would address all of the localized flooding issues by itself and that the flooding is primarily due to the lack of topographic relief within the developed portions of the Project area.” (Source: 2021-09-02 FTN to COF-Drainage Improvement Analysis.pdf, p. 24)

The phrase “lack of topographic relief” is key: this means the land is too flat to drain effectively. This is not a fixable infrastructure problem — it is a permanent characteristic of the terrain. Even with proposed channel improvements, the study found water surface elevation reductions of only 0.25 to 0.8 feet in the best scenarios. (Source: 2021-09-02 FTN to COF-Drainage Improvement Analysis.pdf, p. 24)

A separate stormwater analysis focused specifically on using Lewis Soccer Complex land for flood storage reached a similarly discouraging conclusion:

“Only MINIMALLY EFFECTIVE in lowering flood levels. In most of the flood prone parts of the watershed, the amount of reduction in water surface elevations tops out at a few inches.” (Source: Hamestring_compiled_to_FYV.pdf, p. 1)

The analysis estimated the Lewis Soccer Complex storage scenario would cost $1.5–$2.5 million with a benefit-cost ratio of only 1.47 — far below what most infrastructure projects require for justification. The same report recommends property buyouts as more cost-effective than site development — implying that building on the land creates more problems than it solves. (Source: Hamestring_compiled_to_FYV.pdf, p. 3)

2.3 Development Will Increase Flooding in Adjacent Neighborhoods

The City’s own Stormwater Manager, Alan Pugh, provided language acknowledging the downstream consequences of the project:

Large impervious surfaces such as a water park “increase runoff and infrastructure strain.” (Source: Stormwater Verbiage.eml)
“Stormwater runoff flows downstream, potentially increasing localized flooding in adjacent neighborhoods.” (Source: Stormwater Verbiage.eml)
Development must show it will “not increase flood elevations, channel velocities or flood flows upstream or downstream” — a standard the site may struggle to meet. (Source: Stormwater Verbiage.eml)
Required offsite improvements include full reconstruction of Lewis Avenue — because sections of the road are “too flat to accommodate simple addition of curb,” confirming the inherent drainage inadequacy of the area. (Source: 25304800; Offsite improvement documents.pdf)

One resident, Matthew Klawitter, wrote to city officials asking directly: “What flood mitigation plan is in place to account for all the water displacement that will occur from all this new concrete? Will it ultimately be forced down my street, rather than soaking into the ground, making the flooding by my home way worse than it already is?” The city’s stormwater manager provided a response referencing regulatory requirements but committing to no specific mitigation plan. (Source: RE Wilson Park.eml)

2.4 Wilson Park Pool Was Rejected for the Same Floodplain Reasons Now Being Overlooked at Lewis

“The presence of a floodplain beneath the existing structure, combined with the complexity of obtaining approvals from federal and jurisdiction authorities, renders the site unsuitable for redevelopment.” (Source: Fayetteville Report PDF.pdf — describing why Wilson Park Pool was rejected as a site)

The final feasibility study explicitly rejected Wilson Park Pool as a redevelopment candidate because of its floodplain location and the difficulty of obtaining federal approvals. Lewis Fields has the same FEMA Zone A designation and the same federal approval requirements. The city’s own reasoning for rejecting one site should logically apply to the site it selected. (Source: Fayetteville Report PDF.pdf)

2.5 Wildlife and Habitat Concerns Have Not Been Assessed

Despite the site’s location along Hamestring Creek, no wildlife or habitat assessments appear in the FOIA production. Multiple parties have raised specific concerns:

Lisa Valentine (AGFC Stream Team Leader): “There are endangered birds in the tree canopy.” (Source: RE Aquatics Center.pdf, p. 1)
Valentine also warned against repeating the “Junction at Shiloh” — a prior project that encountered major flooding problems. (Source: RE Aquatics Center.pdf, p. 1)
Resident Helen Ames noted that “residents frequently observe a large bat population feeding along the creek and tree canopy during summer evenings” and asked whether any wildlife or habitat assessments had been conducted. No documentation of such assessments appears in the FOIA record. (Source: Lewis related .pdf, p. 2)

3. PUBLIC OPPOSITION AND INADEQUATE COMMUNITY ENGAGEMENT

3.1 The Public Was Never Asked About Lewis Fields As a Location

The site-selection process deliberately avoided consulting the public about where the facility should be built. The city’s own internal timeline documents confirm:

At the September 2024 steering committee meeting, a site discussion was on the agenda “but it was not really discussed.” (Source: Aquatic Center site selection.pdf, p. 3)
The second public input survey (May 23–June 4, 2025) explicitly did not mention Wilson Park or Lewis Park as candidate locations. (Source: Aquatic Center site selection.pdf, p. 5)
That survey was “restricted to focus on proposed concepts,” and concept images “did not include or reflect location.” (Source: Aquatic Center site selection.pdf, p. 5)
Lewis was ultimately selected based heavily on a “Location Score” in the consultant’s analysis — a score the public never reviewed or validated. (Source: Aquatics info.pdf, p. 5)
The first survey’s key finding — that 50% of respondents want a facility within a 10–20 minute drive — raises questions about whether Lewis (a northern edge of the service area) actually serves the majority of residents. (Source: Aquatic Center site selection.pdf, p. 3)

3.2 Organized Community Opposition

FOIA records document organized and sustained opposition from the Fayetteville community:

A formal community group, “Save Lewis Fields,” is documented in the FOIA production as organizing meetings and communicating formally with city officials. (Source: Lewis Fields.pdf)
Resident Helen Ames sent a formal letter copied to all City Council members and the Mayor’s Office on March 7, 2026, raising concerns about flooding, wildlife, and neighborhood displacement. (Source: Lewis related .pdf, p. 1)
The city’s own parks staff acknowledged Helen Ames’ concerns were substantive enough to require a multi-department response — but could only direct her to city ordinances, not a finalized mitigation plan. (Source: Lewis Site Questions.pdf; Stormwater Verbiage.eml)

3.3 Equity and Displacement Concerns in an Adjacent Vulnerable Community

Lewis Fields is immediately adjacent to Washington Plaza public housing. Nearby Asbell Elementary School serves a student population with a high percentage of children on free or reduced-price lunch. Ames’ letter raises an equity concern with direct backing from planning research:

“The park is adjacent to Washington Plaza public housing, and nearby schools such as Asbell Elementary serve a very high percentage of children receiving free or reduced lunch. Residents have raised questions about the possibility of amenity-driven displacement, where capital projects of this scale can unintentionally increase development pressure in neighborhoods with vulnerable populations.” (Source: Lewis related .pdf, p. 2 — Helen Ames, community letter, March 7, 2026)

The city’s FOIA responses do not include any equity impact analysis, displacement mitigation framework, or community benefits agreement. The city’s only documented response to equity questions was a general statement about its existing scholarship programs — which do not address the broader displacement concern. (Source: Aquatics info.pdf, p. 17)

3.4 Prior Public Surveys Show Lukewarm Support for New Construction

The FOIA production includes 2018 and 2021 public recreation surveys that directly undercut the premise that the community is demanding this project:

In the 2018 survey, constructing an outdoor family aquatic center ranked third among funding priorities. An indoor competition pool ranked eleventh out of nineteen choices. (Source: Aquatic Survey Comments.pdf; Previous Fayetteville Surveys.pdf)
In the 2021 survey, “maintaining what we have before building additional facilities” ranked third overall — the public’s third-highest priority was fiscal conservatism about new construction. (Source: Previous Fayetteville Surveys.pdf)
The feasibility study’s own survey focused primarily on swimming and aquatics program users — a self-selected group — without surveying “neighborhood associations, broader Fayetteville residents, other youth sports groups, or environmental and floodplain stakeholders.” (Source: Lewis related .pdf)

4. LEGAL AND REGULATORY ISSUES

4.1 Federal CLOMR Requirement Creates Significant Delay and Uncertainty

Development within a FEMA Zone A floodplain requires a Conditional Letter of Map Revision (CLOMR) — a formal federal review process that can take 12–24 months and may result in denial. The city’s own engineers have confirmed this will be required:

“Due to presence of zone A along with potential of ponds to show an increase of floodway width, we will need to plan on submitting a CLOMR.” (Source: RE Lewis Park (3).pdf — Crafton Tull engineers)

This CLOMR process is not currently reflected in the project schedule or budget. A denial or significant redesign required by FEMA could invalidate the entire site selection. (Source: RE Lewis Park.pdf; RE Lewis Park (3).pdf)

4.2 City Development Code Creates Additional Compliance Obligations

Development within the Hamestring Creek floodplain triggers compliance requirements under two City of Fayetteville Unified Development Code chapters:

Chapter 168 (Flood Damage Prevention): requires demonstration of no flood elevation increase anywhere in the watershed
Chapter 169 (Physical Alteration of Land): requires compensatory storage for any fill placed within the floodplain

The city’s stormwater manager has confirmed that meeting these standards “will require engineering, permitting, detention systems and long-term maintenance” — costs not currently in the project budget. (Source: Stormwater Verbiage.eml; Lewis related .pdf)

4.3 Fayetteville Public Schools Was Not Formally Consulted Before Site Selection

Lewis Fields is jointly owned by the City (8.5 acres) and Fayetteville Public Schools (FPS) (12.3 acres). Any development on the FPS portion requires the Fayetteville School Board’s formal approval. FOIA emails document that as late as May 2025, the School Board had not yet been consulted:

“I do not think there have been conversations with the BOE to date, only with the Superintendent. I will add this topic to his radar so he may give his input on your plans before we go public.” (Source: RE_ Next steps for aquatics.msg, p. 4 — Dr. Julie Williams, Deputy Superintendent, Fayetteville Public Schools, May 14, 2025)

The site was publicly presented to City Council in September 2025 without confirmation that the School Board had formally approved the use of school district land. (Source: RE_ Next steps for aquatics.msg; Aquatic Center site selection.pdf)

4.4 Contract Issues Flagged by City Finance Staff

The city’s finance review of the contract with design firm Crafton Tull raised multiple red flags:

$175,024 for “Bond Election Efforts” questioned as unjustified (Source: Comments on Contract.pdf)
Payment structure front-loaded on early tasks rather than proportional to deliverables (Source: Comments on Contract.pdf)
Surveying listed as an “extra service” — creating liability ambiguity on geotechnical findings
Appendices were missing from the signed contract; fee computation method unclear
Conflicting language between contract sections describing supplemental services

(Source: Comments on Contract.pdf; Revised Crafton Tull ContractAquatic Facility.pdf)

5. QUESTIONABLE DECISION-MAKING AND PROCESS FAILURES

5.1 City Staff Did Not Trust the Consultant’s Site Analysis

The internal FOIA emails reveal that the city’s own professional staff did not believe the consultant was doing rigorous work, even as that consultant’s recommendation became the basis for a $92 million bond decision. Key exchanges from November 2024:

“I have been disappointed that they seemed to pick plots without giving consideration to or at least providing rationale for their reasoning that reflects the feedback we received from the community.” (Source: Aquatic Center site selection.pdf, p. 3 — Dean Rawlings, Recreation Program Manager, November 8, 2024)

“Dean, I agree with you. They don’t seem to be putting any real effort into site selection. We can talk tomorrow, but I’m still not satisfied with their analysis.” (Source: Aquatic Center site selection.pdf, p. 3 — Alison Jumper, Parks Director, November 11, 2024)

These communications came just two weeks before the consultant produced the final site selection matrix that recommended Lewis Fields. Parks staff were required to repeatedly demand “rationale and justification for each site option” — a basic expectation the consultant apparently was not meeting on its own. (Source: Aquatic Center site selection.pdf, p. 4)

5.2 Site Was Selected to Avoid Land Acquisition Costs, Not Because It Was the Best Fit

The city’s internal site narrative confirms the driving factor in Lewis’ selection was financial convenience:

“Lewis Park scores the highest in this rating. In addition, Lewis Park provided the most benefit with a built-in partnership opportunity with the school district, as well as removing land acquisition cost.” (Source: Aquatics info.pdf, p. 5 — Site Selection documentation)

The facility land study by FPS explicitly identified Lewis’ constraints, including “displacement of multi-use fields,” “cost of building new fields,” and “potential cost of acquiring land for fields.” These are costs being shifted to the school district and the broader community — not eliminated. An alternative site with 103 acres of flat, developable land was identified and passed over. (Source: Aquatic Facility Land Study – FPS.pdf)

5.3 The Proforma Was Incomplete at Critical Decision Points

As late as December 2025 — with the project already publicly announced and the design contract signed — the city’s financial model for the facility was missing fundamental inputs:

Admission rates not finalized
Insurance costs not included
Swim lesson revenue not specified
Razorback Aquatic Club rental commitments uncertain
“Dry side” operational proforma (fitness, courts, meeting rooms) not yet completed
City internal chargeback costs (HR, IT, park maintenance, security) not modeled

(Source: From Lee Farmer.pdf; [External] RE 25304800; Fayetteville Aquatics – Proforma Information.pdf)

Making a $92 million bond commitment with an incomplete proforma means the city does not yet know what annual operating support the facility will require from the general fund.

6. COMPARABLE FACILITY FAILURES AND WARNINGS

6.1 The City’s Own Site Tour Documented Systemic Problems at Peer Facilities

In November 2025, a city team including CFO Steve Dotson, Parks Director Alison Jumper, and other senior staff toured five comparable aquatic facilities. Their internal notes, circulated just before the design contract was awarded, document a pattern of operational failures at peer facilities:

Facility	Problem Documented
Rogers, AR	Original staffing plan called for 25 lifeguards; actual operations require 100. Staffing was significantly underestimated.
Republic, MO	Storm water runoff causes flooding in the facility’s ground-level pumps. Slide crash zone is too short; users can touch the far wall.
Blue Surf	Chlorine smell and humidity significant throughout. Pool office and lifeguard break rooms have no separate HVAC, causing corrosion issues.
Conway, AR	Chemical feeder had design errors requiring replacement post-opening. Outdoor decking showing significant cracking.
Lenexa, KS	Losing significant water from slide runoff due to inadequate drains and recirculation. Added third-party security on weekends.

(Source: Aquatic Site Tour Notes.pdf, pp. 2–9)

The city’s CFO, Steve Dotson, developed a 40-question site-visit framework that included a final question for each facility: “Would you do this again if you had the choice?” The fact that this question was asked — by the CFO, not a skeptic outside the process — signals serious internal doubt about the project’s wisdom. (Source: Aquatic Facility Site Visits.pdf)

6.2 National Comparables Show Pro Formas Consistently Underpredict Real Costs

Park Planning Superintendent Ted Jack’s suppressed December 2025 memo (which his supervisor asked him not to send) compiled national evidence:

Port Townsend, WA: Annual subsidy of $1.3 million — “far exceeding initial projections” (From Ted Jack.pdf, p. 8)
Leavenworth, WA: $21.6M facility study showed $650,000 annual subsidy required, with capital vs. operational tradeoffs unresolved (From Ted Jack.pdf, p. 8)
General pattern: “Pro formas often underestimate operational costs by 20–40%, particularly for staffing and utilities” (From Ted Jack.pdf, p. 8)
Staffing: Industry data identifies staffing as “the largest recurring cost, often underestimated in pro formas” (From Ted Jack.pdf, p. 8)

The Rogers, AR experience — a local, comparable facility — is the most relevant benchmark: a staffing projection of 25 grew to 100 actual employees. Applied to Fayetteville’s pro forma, a 4x staffing underestimate would alone wipe out any projected cost recovery.

7. IMPACT ON EXISTING USE OF LEWIS FIELDS

7.1 Soccer Fields, Green Space, and Permeable Land Will Be Permanently Displaced

Lewis Fields currently serves as a multi-use athletic park with soccer fields used by Fayetteville youth leagues, and as permeable open space that contributes to regional stormwater management. The aquatics facility will displace this use:

The facility requires a minimum of 7.44 acres (164,500 sq ft) of footprint. (Source: Fayetteville Stakeholders Project Progress Meeting.pdf)
An additional 3.67 acres (492 parking stalls) will be paved for parking. (Source: Fayetteville Stakeholders Project Progress Meeting.pdf)
The geotechnical boring investigation alone will “hugely impact programming at the site” during the investigation phase, requiring relocation of soccer fields. (Source: Fayetteville Aquatics Facility.pdf)
The current park serves as “permeable open space supporting regional athletic use,” and its replacement with impervious surfaces will increase downstream stormwater burden. (Source: Lewis Site Questions.pdf)

7.2 The Community’s Own Survey Data Does Not Strongly Support This Project

Before committing to a $92M+ facility, it is worth revisiting what the public’s own stated priorities show:

2018 survey: Building an outdoor aquatic center ranked 3rd in funding priorities; indoor competition pool ranked 11th out of 19 choices. (Source: Aquatic Survey Comments.pdf; Previous Fayetteville Surveys.pdf)
2021 survey: “Maintaining what we have before building additional facilities” ranked 3rd overall — the public’s third-highest priority was fiscal conservatism about new projects. (Source: Previous Fayetteville Surveys.pdf)
Design survey (2025): Gymnasium, indoor track, and fitness space ranked higher than competition pools — yet the competition pool drives the most expensive and highest-subsidy components of the project. (Source: Parks Team Comments.pdf)

8. COUNTERARGUMENTS (WHAT THE CITY WOULD SAY)

A well-rounded argument acknowledges the strongest points on the other side. The following represents the city’s likely responses, drawn from the same FOIA documents:

8.1 “The Feasibility Study Shows Strong Market Demand”

The city’s feasibility study does show favorable demographic conditions: Fayetteville has a younger-than-average population, strong growth trends, and lower-than-average median income (which the study frames as positive for fee-based revenue). (Source: FayettevilleAquaticsFeasibilityStudy_FINAL.pdf, pp. 5–7)

Counter: Market demand and financial sustainability are different questions. The same study that shows demand also states that cost-recovery above 70% is rare and that ongoing subsidies should be expected. Demand does not eliminate a structural funding gap.

8.2 “Lewis Provides a School District Partnership That Benefits Students”

The feasibility study touts the built-in partnership with Fayetteville Public Schools as a benefit, particularly for competitive swimming. The school district expressed support through the Superintendent. (Source: Aquatic Center site selection.pdf; RE_ Next steps for aquatics.msg)

Counter: The School Board was not formally consulted. As of May 2025, the Deputy Superintendent wrote that conversations had occurred only with the Superintendent, not the Board. Without Board approval, the partnership is not binding, and the FPS land (12.3 acres) cannot legally be incorporated.

8.3 “Lewis Scored Highest in the Site Selection Criteria”

The consultant’s site scoring matrix ranked Lewis first, with high scores for accessibility and co-ownership. (Source: 25304800; Site Narrative for boards.pdf)

Counter: The city’s own Parks Director and her deputy privately stated they were dissatisfied with the consultant’s rigor. Lewis’ top score was driven primarily by the factor that the city already owned the land — a cost-avoidance criterion, not a planning quality criterion.

8.4 “The Project Will Serve Low-Income Residents Through Scholarships”

The city’s equity response emphasized existing scholarship programs that provide free or reduced-cost access. (Source: Aquatics info.pdf, p. 17)

Counter: Scholarships address access to the facility but do not address the broader displacement concern — that a major public amenity investment in a low-income neighborhood increases surrounding property values and development pressure, potentially pricing out the residents it was meant to serve. No displacement mitigation framework exists in the FOIA record.

APPENDIX: DOCUMENT INDEX

The following table lists the primary documents reviewed for this analysis. Many FOIA documents appear in multiple numbered copies and “Copy” variants; only the base document is listed here. Documents marked “Email/msg” are Outlook message files or .eml email exports. Documents noted as compilations contain multiple emails chained together.

Filename (base)	Type	Date (if visible)	Key Relevance	Used in Argument
FayettevilleAquaticsFeasibilityStudy_FINAL.pdf	Feasibility Study	Sep 2025	Master cost/market analysis; cost recovery projections; operating deficit acknowledgment	Yes — §1.3
Aquatic Center Estimate Breakdown Contingencies and Bond Package Decisions.pdf	Internal Memo	Jan 2026	Official $92.2M estimate; $10.8M contingency; unfinished geotechnical investigation	Yes — §1.1
2021-09-02 FTN to COF-Drainage Improvement Analysis.pdf	Engineering Report	Sep 2021	Chronic flooding; lack of topographic relief; no single fix works	Yes — §2.2
Hamestring_compiled_to_FYV.pdf	Stormwater Study	2021–2024	Lewis Soccer Complex minimally effective for flood storage; BCR 1.47	Yes — §2.2
From Ted Jack.pdf	Internal Email	Dec 5, 2025	Park Planner warns of subsidy risks; suppressed by Parks Director	Yes — §1.6, §6.2
From Alison Jumper.pdf	Internal Email	Nov 2024	Parks Director admits dissatisfaction with site consultant	Yes — §5.1
From Lee Farmer.pdf	Internal Email	Dec 2025	Proforma missing insurance, admission rates, swim lesson revenue	Yes — §5.3
[External] RE 25304800; Fayetteville Aquatics – Proforma Information.pdf	Email Chain	Dec 2025	Electricity error 5¢→13¢/kWh; competition pool 40–45% recovery; $350–$400K deficit	Yes — §1.4
25304800; Offsite improvement documents.pdf	Engineering/Email	Feb 2026	$2.6M hidden offsite costs; Lewis Ave reconstruction; sewer upgrades	Yes — §1.5
RE Aquatics – Offsite Analysis.pdf	Email Chain	Feb 2026	Public Works confirms downstream capacity issues; calls flood study ‘prudent’	Yes — §1.5
Next Steps Aquatics.pdf	Email Chain	2025	Full program cost $112.9M; school district coordination	Yes — §1.2
Aquatic Center site selection.pdf	Email/Timeline	Nov 2025	Staff criticize consultant effort; survey never asked about Lewis site	Yes — §3.1, §5.1
Aquatics info.pdf	Email with Attachments	Mar 2026	Helen Ames equity/displacement letter; site selection timeline; equity responses	Yes — §3.2, §3.3
Lewis related .pdf	Email Chain	Jan–Mar 2026	Helen Ames bat/floodplain/displacement letter; city responses to community	Yes — §2.5, §3.2
Lewis Site Questions.pdf	Email Chain	Jan 2026	City responses to neighborhood floodplain questions; permeable open space loss	Yes — §2.3, §7.1
RE Aquatics Center.pdf	Email	Dec 2025	Lisa Valentine: floodplain partial, CLOMR needed, endangered birds	Yes — §2.1, §2.5
RE Lewis Park.pdf	Email Chain	2026	FEMA Zone A; CLOMR required; Mt. Comfort culverts at capacity	Yes — §2.1, §4.1
RE Lewis Park (3).pdf	Email	2026	CLOMR may widen floodway; basin complicates hydraulics	Yes — §2.1, §4.1
Stormwater Verbiage.eml	Email	Jan 2026	Stormwater Mgr: impervious surfaces increase runoff; downstream flooding risk	Yes — §2.3, §4.2
RE Stormwater Verbiage.eml	Email	Jan 2026	Parks Director reactions to stormwater responses	Yes — §2.3
RE Wilson Park.eml	Email	2026	Resident flooding questions; city has no finalized mitigation plan	Yes — §2.3
Fw Wilson Park.eml	Email	2026	City sharing flood study materials with consultants post-opposition	Yes — §2.3
Fayetteville Report PDF.pdf	Feasibility Report	2025	Wilson Park rejected for same floodplain reasons now applying to Lewis	Yes — §2.4
Aquatic Site Tour Notes.pdf	Internal Memo	Nov 2025	Site visits: Rogers 25→100 lifeguards; Conway cracks; Lenexa water loss	Yes — §6.1
Aquatic Facility Site Visits.pdf	Internal Memo	Nov 2025	CFO Dotson’s 40-question skeptic framework; ‘Would you do this again?’	Yes — §6.1
25304800; Site Narrative for boards.pdf	Internal Doc	2026	Lewis selected to avoid land acquisition; staff wanted more justification	Yes — §5.2
Aquatic Facility Land Study – FPS.pdf	Land Study	2025	Lewis constraints listed; alternative 103-acre FPS site available	Yes — §5.2
Fayetteville Aquatic Feasibility Study Potential Land Sites.pdf	Site Analysis	2025	18 sites evaluated; Lewis chosen on cost-avoidance criteria	Yes — §5.2
Previous Fayetteville Surveys.pdf	Survey Data	2018, 2021	Maintaining existing facilities ranked 3rd; competition pool ranked 11th	Yes — §3.4, §7.2
Aquatic Survey Comments.pdf	Survey Data	2018	Competition pool ranked 11th of 19 funding priorities	Yes — §3.4
Parks Team Comments.pdf	Internal Memo	2025–2026	Staff questions on estimate reliability, concession crowding, unit costs	Yes — §1.2
Comments on Contract.pdf	Finance Review	2025	Contract irregularities: $175K bond fees questioned; appendices missing	Yes — §4.4
Revised Crafton Tull ContractAquatic Facility.pdf	Contract	2025	LEED conflict; competition pool listed as ‘possible phase’; CAD refusal	Yes — §4.4
Questions Regarding Lewis Park Floodplain and Aquatic Facility Proposal.eml	Citizen Letter	2026	Formal community floodplain questions; city evasive in response	Yes — §2.1
Lewis Fields.pdf	Email/Doc	2026	Save Lewis Fields opposition group documented	Yes — §3.2
Lewis Park.pdf	Email	2026	Engineering consultation on floodplain; no-rise requirement confirmed	Yes — §2.1
Fayetteville Stakeholders Project Progress Meeting.pdf	Meeting Deck	2025	492 parking stalls (3.67 acres); 7.44 acre minimum footprint	Yes — §7.1
Fayetteville Aquatics Facility.pdf	Email	Mar 2026	Geotechnical boring will ‘hugely impact’ soccer programming	Yes — §7.1
RE_ Electric Rates for the proposed Aquatic Center.msg	Email	2025	Electric rate correction confirms cost underestimation	Yes — §1.4
Equity Questions from Save Lewis Meeting.msg	Email	2026	Opposition group equity questions; city responses noncommittal	Yes — §3.3
RE_ Thoughts on Aquatics.msg	Email	Dec 2025	Internal candid discussion of subsidy expectations	Yes — §1.6
RE_ Fayetteville AR Aquatic Feasibility Study Final Draft-2.msg	Email	2025	Final draft review; unresolved internal concerns	Supporting
RE_ 25304800_ Fayetteville Aquatics Questions for Pro Forma.msg	Email Chain	2025–2026	Pro forma discussions; incomplete financial modeling	Supporting
RE_ 25304800_ Site Selection – Fayetteville Aquatic Center.msg	Email	2026	Site selection process communications	Supporting
Site Selection Site Visit Notes.pdf	Internal Doc	Nov 2025	Staff tour notes; Rogers 25→100 lifeguards	Supporting
Concept Review Updated Site Acquisition.pdf	Analysis	2025	Updated site scoring; Lewis ranks 1st on cost-avoidance criteria	Supporting
Wilson Pool + Park Land Acquisition.pdf	Analysis	2024	Initial 15-site evaluation; multiple viable alternatives existed	Supporting
Aquatics Feasibility Study DRAFT.pdf	Draft Study	2025	Earlier cost range $59.8M–$107.3M; Year 1 deficit projections	Supporting
Aquatics questions.pdf	Email	2025	Community questions about process and costs	Supporting
all emails.pdf	Compiled Emails	2024–2026	Compilation of major email threads; contains Helen Ames letter	Supporting
RE Aquatics Center (1).pdf	Email (duplicate)	Dec 2025	Duplicate of RE Aquatics Center.pdf	Duplicate
Screenshot 2026-03-11 (3 files).png	Screenshots	Mar 11, 2026	Unread image files; may contain additional context — recommend visual review	Unread — images

Note: Files marked as “Duplicate” are byte-for-byte identical to another listed file as confirmed by MD5 hash comparison. Files marked “Supporting” were reviewed and are consistent with the arguments above but do not add distinct additional evidence.

Prepared from FOIA records obtained from the City of Fayetteville, Arkansas. All claims trace to documents in the Relevant subfolder. Document review conducted March 2026. Every quotation in this document is a verbatim excerpt from a City of Fayetteville record. No quotations have been condensed, paraphrased, or taken out of their immediate documentary context without notation.

Save Lewis Park

CASE AGAINST LEWIS FIELDS AQUATIC FACILITY

EXECUTIVE SUMMARY