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NASIL hereby seeks recognition by USSF as a Division Men's Outdoor Professional '-
1
Soccer League.

While classifying pmfesslonal soccer leagues into different competitive divisions is

common around the world, it is universally based on the principle of promotion and
relegation. USSF, however, has classified professional leagues into wholly separate
divisions. FIFA does not require Member Associations to classify their member leagues
as diffe1·ent divisions, but endorses the principle of promotion and relegation, and states
that a Club's entitlement to take part in a domestic league championsh ip shall depend
principally on sporting merit.1

NASL meets all USSF requirements for Division I apart from two criteria that are not
a legitimate basis to exclude a league from Division I. Accordingly, if USSF insists on
classifying professional leagues into different competitive d ivisions, USSF should
recognize NASL as a Division I Men's Outdoor Professional Soccer League.

NASL was admitted as Professional League member of USSF pursuant to the USSF
Bylaws in February 2012. Pursuant to USSF Policies, NASL was classified then as a
Division II Men's Professional Outdoor Soccer League. The USSF Policy Manual states
that the USSF Board of Directors shall establish standards to certify the cornpetitive
division designation of a Professional League member that operates a professional
soccer league.

NASL currently meets all of the requirements set forth in the General Requirements
for all Professional Leagues apart from the requirement of a field-size waiver from '
'' l
Jacksonville Armada. The Armada currently play on a pitch that is 103 x 76 but will have
a fully compliant pitch by 2018 after construction of a soccer-specific stadium.

In addition to meeting all of the Standards set forth in the General Requirements,
NASL meets all of the Standards to operate a Division I Men's Outdoor Professional
Soccer League, except for two improper criteria relating to (1) geographic location
and (2) stadium capacity, that are arbit rary in nature and have no meaningful value
in determining whether a league merits the Division I classification. These criteria are
improper barriers to competing as a Division i league. ; l

1 See FIFA Regulations Governing the Application of the Statutes - Article 9.

u
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GEOGRAPHIC LOCATION
NASL Clubs currently operate in each of the Eastern,
Central and Mountain time zones. When USSF adopted
the Standards for professional leagues in 1995, the
r Standards required that a Division I league operate teams
in only three U.S. time zones. Thus, NASL would meet
I that standard. However, the Standards were revised in
2008 so that a league must feature teams in at least
three time zones within the continental United States.
I The Standards were then further modified in 2014 to
require that a Division I league feature teams in the
Eastern, Central and Pacific time zones. Although the
Standards themselves state that this requirement aims
to ensure that a league services a sufficient population
base, the Eastern, Central and Mountain time zones cover
approximately 85% of the population of the United States
and Canada. Replacing the Mountain time zone with the
Pacific time zone yields a gain of only 7%. Coupled with
this is the fact that the Mountain time zone is only one
hour removed from both the Pacific and Central time
zones, ensuring access for an extremely large swathe
of potential viewers. There is simply no legitimate basis
to require a presence in the Eastern, Central and Pacific
time zones, while discounting entirely any presence in
the Mountain time zone. This is thus not a proper basis to
deny Division I certification. In any event, NASL expects
that it will have clubs competing in all four continental
time zones by 2017.

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STADIUM CAPACITY
NASL Clubs currently feature an average stadium capacity of 10,692 and an average attendance of 6,335. The
Standards include a requirement that all stadiums in a Division I Men's Outdoor Pmfessionai !eague feature
spectator capacity in excess of 15,000. This Standard creates an unnecessary and unreasonable barrier to entry
because (i) stadium capacity is not relevant to whether a league is or is not of Division 1 qua!ity, (ii) it is more
difficult for a professional team to sustainably build a soccer stadium in excess of 15,000 when it is playing in a
league that has been labeled with a Division II designation, and (iii) a league would be disqualified from Division
1 status if even one stadium in the league has less than a 15,000 capacity, which is illogical and has no bearing on
whether the league overall is or is not of "Division l" quality.
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STADIUM CONSTRUCTION
The arbitrary nature of the USSF stadium capacity requirement is self-evident from a quick glance at the Barclays
Premier League. A.F.C. Bournemouth has just won promotion to the Premier League with a stadium capacity
of 11,700, and will ptay in that same stadium with that same capacity in the Premier League. Other teams have
similarly played in the Premier League in stadiums with a capacity below 15,000. No one would seriously
question that the Barclays Premier League is one of the preeminent football leagues in the world, yet under the
USSF standards the Premier League would not meet the stadium capacity qualification for Division 1.

Moreover, a major component of stadium construction financing revolves around the quality of the programming
hosted at the stadium. Due to the USSF designation and the constant portrayals of NASL as a "second-tier"
league by other USSF Organization Members, the marketplace mistakenly associates NASL with an inferior
product, for reasons having nothing to do with the actual competitive merits of NASL clubs. This has resulted in
public and private entities expressing reluctance to finance any soccer stadium construction unless such projects
are affiliated with a Division ! I MLS team. NASL's lack of Division I status is thus precisely what prevents it from
meeting this unreasonable Division I requirement.

Stadium size also i1as little bearing on driving attendance. In fact, over the years MLS teams have downsized
many of their stadiums to eliminate excess stadium capacity that harmed the fan experience at games. As we
have seen. a compelling product on the pitch and marketing efforts in the community drive attendance.
Indeed. notwithstanding the limitations of currently being labeled as Division II, Jacksonville Armada FC, Indy
Eleven and New York Cosmos are all in discussions to build soccer-specific stadiums with capacity well in excess
of 15,000 seats. Not surprisingly, their plans are based on strong demand for ticket sales and a commitment to
their communities. In addition, Tampa Bay Rowdies are developing plans for the potential expansion of their
current stadium and the San Antonio Scorpions' Toyota Field was ready-built for expansion. Once the barrier
to entry posed by NASL's "second-tieru label has been lifted, we expect that further stadium expansions will
become increasingiy commercially feasible as attendance increases further.

!-----.;

LJ
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APPLICATION MATRIX

I
Standard ii (ll.b.il)
Market Size i Stadium ! Performance i Principal i PO Net Worth ii Group
i capacity ! Bond (ll.c.i) i Owner ("PO") i of $40MM
Ownership i Team Staff l Reserve ii Youth
Net Worth i Compliance i Team Devel-
I 1 I( 11.1:).111) I I(ll.c.ll) 1Cll.c.ii) j of $70MM (ll.cJI) j (ll.e.l) 1(ll.e.il) 1
.......
l ! 1 1 1 l Vss

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Ers;,ll
Q;;:demi•
Yes
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Minnesota
UnltadFC
3,459,146 Yes Bill
McGuire
Yes
BY 2016

Seamus
O'El!rkm
f-JewV::,f"..:

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!·. 'i,2l5,.324 1
. .;M,OOO . !· .. :. Yes .\ Yftl;;; Y!!'ls ;,' Yes

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2,277,5!50 ·. '· Yss. . ·,.1 1,. 1,
. Yes
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r<l!t<mt t=c I 5,76:!,7'11 I TBO I "Yes Riccardo Silva I Yes I Yes Yes I I
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