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the bonds. The General Assembly cannot levy a tax for the purpose of servicing the debt of special
obligation bonds.1
The major sports facility bonds in H.B. 96 would only be backed by the increased tax
revenues generated by the transformational major sports facility mixed-use development.2
Therefore, they are special obligation bonds, and more specifically revenue bonds. The
constitutional prohibition on GO bonds would not prohibit these bonds as written, but whether
they are authorized special obligation bonds is another matter.
Constitutional authority
The Revised Code currently gives the General Assembly the authority to issue bonds for
the construction of Ohio sports facilities.3 However, there does not seem to be a constitutional
provision that specifically authorizes issuing bonds for sports facilities.
The authority to issue special obligation bonds comes from Ohio Constitution, Article VIII,
Section 2i, in the second to last paragraph. This paragraph permits special bonds for the capital
improvements:
for mental hygiene and retardation, parks and recreation,
state supported and state assisted institutions of higher education,
including those for technical education, water pollution control and
abatement, water management, and housing of branches and
agencies of state government.
This does not mention sports or cultural facilities, even though this section is commonly
cited as permitting cultural and sports facilities.4 It may fall under “parks and recreation.” The
Revised Code section authorizing these bonds lists parks and recreation separately from cultural
and sports facilities, and the two have different funds.5
However, a sports facility may be considered as “housing an agency of state government.”
Corbett Case
In 1993, a group of taxpayers sued the Ohio Building Authority, attempting to enjoin them
from selling bonds to pay for the Cincinnati Performing Arts Center. They claimed it was not
permissible under Section 2i, as the facility would not “house” a state agency – in this case, the
Ohio Arts Facilities Commission (OAFC).
The court sided with the state, saying that 1. The Revised Code stated the functions of the
Commission in providing for the development, performance and presentation of the arts include

1 Article VIII, Ohio Constitution.

2 R.C. 123.28 and 123.281, as amended by the bill.
3 R.C. 123.28, 123.281, 154.02(Ai)(5), and 154.23.
4 See, e.g., OBM’s page on bonds at obm.ohio.gov/bonds.
5R.C. 154.02. There is the Parks and Recreation Improvement Fund (Fund 7035), and the Cultural and
Sports Facilities Building Fund (Fund 7030).

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“the provision, operation, and management of Ohio arts facilities;” and 2. That “housing” was
not so narrow as to only mean office space; it encompassed the Commission’s duty to “[o]wn,
lease, equip, furnish, administer, and manage Ohio arts facilities,” and included “personnel,
equipment, or functions” of the OAFC.
Thus, the court found these special obligation bonds for arts facilities were permissible.6
The same reasoning potentially applies to sports facilities. Currently, Ohio sports facility
projects are administered by the Ohio Facilities Construction Commission (OFCC), which may be
the agency “housed,” per the Corbett case reasoning.
A reviewing court might compare the proposed major sports facility with the Cincinnati
Performing Arts Center, examining whether the stadium would “house” the OFCC within the
meaning of Section 2i.
Under the bill, the state is required to maintain a sufficient property interest in the
stadium such that it maintains “the right to use or to require the use of the major sports facility
for the presentation of sport and athletic events to the public.”7
Ultimately, only a court can determine whether or not it is permissible.
Economic Impact
An economic impact analysis of the proposed domed stadium and mixed-use
development in Brook Park was conducted by consulting firm Robert Charles Lesser & Co. (RCLC)
on behalf of the Haslam Sports Group (HSG). While LBO was unable to obtain the full report, the
executive summary is publicly available as well as the slides presented to the House Arts,
Athletics, and Tourism Committee on March 11, 2025 by Ted Tywang, Chief Administrative
Officer and General Counsel of HSG. LBO also acquired a research memorandum authored by
Econsult Solutions, Inc. (ESI) for the law firm Squire Patton Boggs. The memorandum estimates
the potential net losses of economic impacts for the City of Cleveland resulting from the
relocation of the Browns’ home stadium to Brook Park and analyzes the market potential for the
Brook Park site. All three of these documents are attached to this memorandum.
Since the executive summary of RCLC’s analysis does not list many assumptions the firm
made or provide the sources of all data employed, LBO is unable to evaluate the analysis in full
detail. However, when interpreting the projections of RCLC’s analysis, it is useful to consider the
academic literature as it provides numerous case studies and investigations on the topic.
Impact on Employment
The analysis conducted by RCLC claims that the Brook Park project will support 6,000
temporary construction jobs, 5,370 permanent full-time equivalent (FTE) jobs at the site, and
2,540 indirect and induced jobs in Cuyahoga County. An FTE job is a unit of measure used to
represent the workload of a fully employed person and may be comprised of more than one

6 Corbett v. Ohio Bldg. Auth., 86 Ohio App.3d 44, 52 (10th Dist.1993).

7 R.C. 123.281(H)(4)(b) of the bill.

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employee. For example, two jobs employing workers for 20 hours a week each sum to a single
FTE job.
The projected FTE jobs in Brook Park are comprised of 870 at the stadium, 2,520 in the
adjacent mixed-use district to be constructed, and 1,980 at surrounding businesses. It is likely
that the 870 stadium jobs will be mostly, or all, relocated jobs from the Browns’ current stadium
in Cleveland. Therefore, they should not be considered new jobs, but relocated jobs. To a lesser
extent, the same may be said for the projected 2,520 FTE jobs in the mixed-use district. Insomuch
as the district pulls demand for the goods and services provided away from Cleveland, some of
the newly created positions in the mixed-use district will come at the expense of similar jobs in
Cleveland.
The projected 1,980 FTE jobs in surrounding businesses is likely an estimate derived from
assumptions on what are called “multiplier effects”. Multiplier effects are those derived from the
secondary circulation of money that was initially spent due to the new development. That is,
some of the additional revenues generated by, for example, a winter concert in the new domed
stadium will be used by HSG to purchase local goods or services. This secondary spending may
cause the suppliers to the stadium to hire more workers or increase the hours of those already
employed.
For example, the stadium may contract with a local promoter to advertise the additional
winter concerts, who may, in turn, increase the hours of his employees. Academic literature on
the employment of such methods documents frequent misuse of multiplier effects to inflate the
reported economic impacts of sport stadiums.8 However, since the publicly available executive
summary does not describe the methods used in detail, LBO is unable to critique the multiplier
effects assumed in RCLC’s executive summary.
The projected 2,520 indirect and induced jobs in Cuyahoga County are also likely derived
from assumed multiplier effects. Indirect jobs refer to those created due to increased demand
for the goods and services of suppliers and vendors to the stadium. The example of the promoter
increasing the hours of his employees above is an example of an indirect job (or partial FTE job).
Induced jobs are estimated in a similar fashion but are based on the spending of increased wages
received from the initial job creation. For example, some of the additional income received from
employees staffing the winter concerts will be spent locally, perhaps at restaurants. The
additional spending at restaurants may necessitate additional waiters and cooks, or more hours
worked by those already employed.
Similar to the projected permanent FTE jobs in Brook Park, LBO is unable to critique the
assumed multipliers used for the indirect and induced jobs in Cuyahoga County as their values
were not provided in the executive summary. RCLC does not include an explanation of how the
reported 6,000 temporary construction jobs were projected. Therefore, LBO cannot directly
critique the figure as it is not clear how it was constructed or whether it also involves multipliers.

8Crompton, J. L. (1995). Economic impact analysis of sports facilities and events: Eleven sources of
misapplication. Journal of sport management, 9(1), 14-35.

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Lacking detailed information on how RCLC derived their projections, it is perhaps useful
to consider what the academic literature has found on the topic. A recently published peer-
reviewed article by three leading sports economists surveyed the literature on the economic
impacts of sports stadiums.9 The authors largely find that the decades of research failed to find
significant impacts on employment from the construction of new sports stadiums.
For instance, one surveyed article examined the employment effects of the Colorado
Rapids of Major League Soccer leaving Mile High Stadium in Denver (home of the NFL’s Denver
Broncos) for a newly constructed suburban stadium, similar to what is being proposed by HSG.
Neither stadium site was found to have had a significant impact on employment. Note that is not
to say that jobs were not relocated from Denver to the suburbs, but rather that the effect was so
small that it did not register in the statistical analysis.
Although the literature fails to find an overall positive impact on employment, some
studies were identified that found small local positive effects on employment complementary to
sports consumption, such as eating and drinking establishments within a mile of the stadium.
Impact on Economic Growth
RCLC’s analysis suggests that the mixed-used development focused around a sports
stadium anchor will serve as a catalyst for future economic growth in Cuyahoga County based on
several economic studies. Three similar sites are listed as examples of successful projects that
spurred further economic growth: (1) The Battery in Atlanta, GA, (2) Titletown in Green Bay, WI,
and (3) the Deer District in Milwaukee, WI. The economic studies were not listed in the executive
report and so may not be directly evaluated.
However, the academic literature does contain a study on the impact of Major League
Baseball’s Atlanta Braves moving from the city to the The Battery, which is located in Cobb
County, GA. The journal article focuses on commercial assessment values, which should reflect
the value of the businesses housed in the properties. The author states,
Cobb assessment values did not increase relative to other
metro-Atlanta counties following the stadiums’ announcement or
opening, which is inconsistent with the stadium having a positive
fiscal impact, even with its desirable location and accompanying
mixed-used development. The findings are consistent with past
economic studies and are likely generalizable to other stadium
projects.10
RCLC’s executive summary states, “A dome stadium would be additive to attracting
different types of major events to Northeast Ohio and generally not competitive to Rocket

9Bradbury, J. C., Coates, D., & Humphreys, B. R. (2023). The impact of professional sports franchises and
venues on local economies: A comprehensive survey. Journal of Economic Surveys, 37(4), 1389-1431.
10 Bradbury, J. C. (2022). Does hosting a professional sports team benefit the local community? Evidence
from property assessments. Economics of Governance, 23(3), 219-252.

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Mortgage Field House”. 11 On the same page, the report states, “data shows that events are a
substitute for travel and entertainment.” These two statements are contradictory. Economic
theory agrees with the latter: entertainment options at venues such as Rocket Mortgage Arena
would be substitutes for those at a new Brook Park site. For example, an individual cannot attend
a Taylor Swift concert at the proposed domed stadium and a Cleveland Cavaliers game at
Mortgage Arena simultaneously. Even if the events are held on different days, the consumer has
a limited budget and may not be able to afford both.
Impact on Economic Activity
RCLC projects $11 million in additional spending at bars, restaurants, and hotels in
downtown Cleveland due to the proposed Brook Park mixed-use development. The authors claim
that the stadium will attract an additional 1.5 million visitors, many of whom are assumed to stay
in downtown Cleveland after visiting Brook Park. The report also states that 40% of visitors to
Huntington Bank Field in 2024 were from out-of-state and that 65% to 75% of visitors at events
similar to those held at domed stadiums were from out-of-state. Comments made by Chief
Administrative Officer and General Counsel of HSG, Ted Tywang, at the House Arts, Athletics, and
Tourism Committee meeting on March 11, 2025 imply that these statistics are derived from ticket
sales and are likely accurate.12 The implication is that a domed stadium in Brook Park would allow
for more events that would attract crowds comprised mostly out-of-state visitors.
According to the Venues Design Director at HKS, the Texas-based architecture firm
employed by HSG, the proposed stadium in Brook Park will have a capacity up to 70,000 visitors,
approximately 3,000 more than Huntington Bank Field. Given the stated average 10 games per
season played at home by the Browns, the new stadium would allow for approximately 30,000
more visitors for NFL games.13 This leaves 1.47 million of the additional visitors to be explained
by additional events held at the stadium, equivalent to exactly 21 sold-out events. According to
the attached study by Econsults, none of the three closest domes had more than 12 major events
(attendance of at least 50,000) in 2023.14
The authors also found that the three comparison domes hosted between four to 10
smaller events, such as high school tournaments, conventions, and motocross, but did not list an
average attendance of these events. If we instead assume that smaller events at the new Brook
Park stadium occupy 50% of the stadium capacity (i.e., 35,000 visitors), and 10 smaller events are

11RCLCO Real Estate Consulting. (2024) (Executive Summary) Market Feasibility and Fiscal/Economic
Impact. static.clubs.nfl.com.pdf.
12 ohiochannel.org/video/ohio-house-arts-athletics-and-tourism-committee-3-11-2025.
13 With a 17-game schedule, each NFL team hosts eight or nine home games per season. The 10-game
average may include assumed playoff appearances or preseason games. It is more likely that preseason
games, which may be one or two per season, is included in the figure as the Browns have not had a home
playoff game since 1995.
14 Ford Field in Detroit is reported to have hosted 12 major concerts or events, U.S. Bank Stadium in
Minneapolis was reported to have had six such events, and Lucas Oil Stadium in Indianapolis was reported
to have had four.

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held in addition to 12 sold-out major events with 70,000 visitors – all of which would not occur
in any other Ohio stadium otherwise – and that the additional stadium capacity compared to
Huntington Bank (3,000) is fully utilized for every Browns game, the Brook Park stadium would
only attract 1.22 million new visitors, not 1.5 million.15 It is important to emphasize that this
calculation assumes an optimistic scenario relative to the experiences in comparable cities,
suggesting that the estimated 1.5 million new visitors may be overly optimistic.
RCLC’s report does not consider how many of these additional events will be relocated
from other in-state stadiums. For example, Major League Soccer’s Columbus Crew, who are also
owned and operated by HSG, relocated their home game against Inter Miami this season to
Huntington Bank Field. The purpose of the move was to capitalize on the increased demand to
watch Inter Miami’s Lionel Messi, widely considered to be the greatest soccer player of all time.
The increase in economic activity in Cleveland was therefore created at the cost of revenue that
would otherwise have been generated in Columbus. It is likely that future matches where
Columbus play teams with international stars will be relocated to the proposed stadium in Brook
Park, thereby relocating economic activity away from Columbus.
Impact on Cleveland
RCLC cites a projected $10 million loss in tax revenue to Cleveland and mention the
necessity to consider the city’s cost savings on annual debt service, maintenance, capital repairs,
insurance, and other gameday operating costs it is required to pay for under the lease agreement
with the Browns. However, since the city owns the building and land, it will likely continue to
incur maintenance, repair, and insurance costs unless the building is demolished, which would
also incur a substantial cost.
The source of the $10 million figure reported by RCLC was not listed, so LBO is unable to
evaluate this claim. The attached study carried out by Econsult reports a projected $11 million
cost in lost tax revenue for the city. However, many of the criticisms of the RCLC study may also
apply to that analysis as the figure is comprised of direct, indirect, and induced tax revenue.
Conclusion
The academic literature on publicly funded sports stadiums is vast, covering many
decades, sports, states, and municipalities. The overwhelming conclusion from this body of
research is that there are little to no tangible impacts of sports teams and facilities on local
economic activity. A second conclusion is that the level of government subsidies given for the
construction of facilities far exceeds any observed economic benefits when they do exist. RCLC’s
executive summary contains claims that contradict these widely known research findings, but
LBO cannot verify RCLC’s claims because the source material and methodology were not
documented in full detail.
Of final note, RCLC’s executive summary cautions against using its projections for the
purpose of financing the stadium. The final paragraph states,

15 (35,000 × 10) + (70,000 × 12) + (3,000 × 10) = 1,220,000.

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This report is not to be used in conjunction with any public

or private offering of securities or other similar purpose where it
may be relied upon to any degree by any person other than the
client without first obtaining the prior written consent of RCLCO.

Further Questions
Please let us know if you have any more questions. If you seek further information about
the bond issuance or constitutional aspect, you may reach
. If you have further questions about the economic impact commissioned
by the HSG, please contact .

Attachments: R_136_1110 Econsult.pdf

R_136_1110 RCLC.pdf
R_136_1110 slideshow.pdf

R-136-1110/jw

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