Publication date: October 15, 2026
Jurisdiction: City of Ardmore, Carter County, Oklahoma
Primary municipal site: Ardmore Regional Park, 2704 N. Rockford Road; North Softball Complex identified in the 2023 minutes as 3045 Softball Complex Road.
Related but separately named locations: “Ardmore Youth Baseball” event venue label (historically listed near I-35/Veterans Boulevard) and Cardinal Park Southeast Baseball/Softball Complex (1002 East Main Street).
Study periods: Historical USSSA research architecture, 2001–2026 (Ardmore-linked direct records visibly date 2002–2026); municipal actions and available agreements, especially 2000, 2022, 2023, 2025 and 2026.
Editorial standard: Documented decisions and calculated activity are distinguished from allegations, receipts, operational outcomes and records still needed. No wrongdoing is alleged in this article.
The public-benefit question: When the City approves community nonprofit use of taxpayer-supported diamonds, and later authorizes substantial capital investment, what evidence demonstrates affordability, fair access, facility stewardship and lasting benefit to children, families, and volunteers?
Executive finding: the City has put actual decisions on the record
The June 20, 2023 Ardmore City Commission minutes record approval of two separate YMCA arrangements concerning Ardmore Regional Park: concession operations and use of the four-field North Softball Complex. Parks and Recreation Director Teresa Ervin presented the items. The concession presentation described a YMCA concession relationship dating to March 2000 and explained that the YMCA was to pay the City a percentage of concession gross sales; the minutes do not supply the percentage or actual remittances. The field-use item said the YMCA had provided community youth activities for years and would be allowed to use four fields at 3045 Softball Complex Road. Both motions passed unanimously. [S2]
These 2023 agreements are not the same as every USSSA event in a 2001–2026 dataset. The publicly reconstructed tournament records include naming variations, an “Ardmore Youth Baseball” label, and several directors or organizations. A municipal agreement with the YMCA does not establish that the YMCA hosted, collected entry fees for or controlled any particular USSSA event. [S2][S7][S8]
The public investment record provides another test. On July 7, 2025, commissioners unanimously approved a $1,623,613.82 contract for artificial turf installation on eight baseball/softball infields and two playgrounds at Regional Park, within a stated $1.7 million budget. A January 20, 2026 agenda packet subsequently proposed a $56,919.72 change order and described a revised contract amount of $1,680,533.54. The agenda document is evidence of a proposed amendment; this episode has not independently verified the final vote, payments, acceptance, or close-out. [S4][S5]
What is not established: These sources do not tell us actual tournament entry-fee collections, which director deposited them, how many events used the four YMCA-designated fields, how competing reservations were allocated, actual concession percentages paid, completed annual capital expenditures, or whether local registration prices fell after improvements. Those are the next evidence questions, not misconduct findings.
1. Facility ownership, municipal authority and the precise field boundary
The City of Ardmore identifies Ardmore Regional Park at 2704 N. Rockford Road as a public park with multiple amenities, including softball complexes, soccer fields, courts, trails and other recreation infrastructure. The City Commission is the documented voting body for the 2023 agreements and 2025 turf contract. Parks and Recreation staff presented operational and capital recommendations; presentation is not itself a City Commission vote. [S1][S2][S4]
The June 20, 2023 North Softball Complex agreement concerns four specified fields at 3045 Softball Complex Road. The separate Cardinal Park agreement concerns a different facility at 1002 East Main Street. The Cardinal Park minutes discuss City-paid water and electricity, YMCA maintenance, community leagues and need-based fee scholarships. Those explicitly described Cardinal Park terms must not be assumed to be terms of the Regional Park North Softball Complex agreement without its executed text. [S2][S3]
Ardmore's website separately publishes agendas for a Regional Park Authority and for the Parks and Recreation Advisory Board. Their names and meeting pages do not establish that either body approved the cited YMCA contracts or has delegated power over every tournament. The votes confirmed here belong to the City Commission. [S9]
2. Primary municipal evidence: decisions, actions and limits
| Date | Decision or source | Precisely documented responsibility and evidence limit |
|---|---|---|
| April 4, 2022 | City Commission agenda considered a Youth Scoreboards, LLC ground sublease involving electrical service to eight Regional Park scoreboards/video boards and a City amount not to exceed $100,000. | Agenda item only verified here. It is not a verified payment, completed contract or confirmed individual vote. Obtain adopted minutes, signed instrument, invoices and electrical bills before drawing conclusions. [S6] |
| June 20, 2023 | YMCA concession operating agreement for Regional Park approved, effective July 1, 2023–June 30, 2024 with described automatic-extension language. | Collective City Commission action. Vice-Mayor Sjulin moved; Commissioner Credle seconded; Pfau, Credle, Plesher, Sjulin, Ellis voted aye. Staff said concessions had been under YMCA contract since March 2000 and the YMCA pays a gross-sales percentage, not disclosed in the minutes. [S2] |
| June 20, 2023 | YMCA field-use agreement approved for Regional Park North Softball Complex, four fields. | Collective action. Commissioner Pfau moved; Commissioner Plesher seconded; all five voted aye. Teresa Ervin presented. Do not equate use of four named fields with control of all eight infields or all USSSA events. [S2] |
| June 20, 2023 | Cardinal Park YMCA field-use agreement approved separately. | Different public site, different agreement. Minutes specifically mention YMCA field maintenance, sports leagues and fee scholarships in the Cardinal Park presentation; those details are not automatically transferable to Regional Park. [S3] |
| April 7, 2025 | City Commission awarded a five-year Parks and Recreation beverage contract with $11,400 guaranteed annual revenue plus potential product rebates, affecting numerous City venues including Regional Park and Cardinal Park YMCA fields. | Commissioner Plesher moved; Vice-Mayor Credle seconded; Ellis, Plesher, Credle, Sjulin voted aye; Pfau was absent. The $11,400 is program-wide, not Regional Park revenue alone; performance and actual collections are unverified. [S10] |
| July 7, 2025 | $1,623,613.82 turf/surfacing installation agreement for eight infields and two playgrounds, with $1.7 million budgeted. | Commissioner Sjulin moved; Commissioner Ellis seconded; Pfau, Ellis, Sjulin, Plesher, Credle voted aye. Contract authorization is not audited expenditure or evidence of final completion. [S4] |
| January 20, 2026 | Published agenda packet recommended a $56,919.72 turf-project change order, increasing proposed total to $1,680,533.54, citing drainage and unexpected rock work. | Staff proposal/agenda evidence, not a verified final vote or disbursement in the sources reviewed. [S5] |
Renewal-date clarification needed: The June 2023 minutes describe an initial July 2023–June 2024 term, up to two annual automatic extensions, and also a July 1, 2027 renewal date. These descriptions merit comparison with the executed agreements and notices; the meeting summary alone does not resolve precisely which dates and renewal conditions governed in 2026. [S2]
3. Historical Hidden Valley/USSSA activity — three separate venue labels
The September 20, 2026 Hidden Valley sports-facilities inventory provides row-level counts for three stand-alone Ardmore-associated venue configurations. A label that names a youth-baseball organization is not by itself proof of the physical ballfield used. The 2001–2026 label is the statewide research window; the identified local records run 2002–2026. [S7][S8]
| Historical primary-facility label | Divisional record rows | Team entries | Calculated entry fees | Minimum games | Modeled officials |
|---|---|---|---|---|---|
| Ardmore Regional Park (exact single-facility label) | 76 | 1,928 | $674,675 | 5,917 | 11,793 |
| Ardmore Youth Baseball (organization/venue label; exact field to verify) | 72 | 1,735 | $529,815 | 3,881 | 7,753 |
| Ardmore Regional Park, Ardmore Youth Baseball (joint label, not two separate sets of teams) | 3 | 177 | $65,136 | 528 | 1,056 |
| Direct/stand-alone Ardmore-associated TOTAL | 151 | 3,840 | $1,269,626 | 10,326 | 20,602 |
Terminology: 151 means division-level data rows across the three direct venue configurations, not 151 unique age categories or 151 independent events. The facility inventory lists 50 events under exact “Ardmore Regional Park,” 38 under “Ardmore Youth Baseball,” and 3 under the joint label; these are label-level event counts, not a de-duplicated total of unique event IDs across the group. The direct inventory identifies 15 associated directors/organizations across the group in its published facility-summary accounting. The 63 league-team entries and $1,374 calculated league fees are subsets of the published direct activity, not amounts to add again. [S7][S8]
The historical facility summary attributes $1,099,481 to baseball and $170,145 to softball across the direct/stand-alone Ardmore-associated group. The published calculation is participating team entries × publicly listed team entry fees. It is not a cash-receipts ledger, IRS finding, amount paid to the YMCA, City rental income, concession profits, tax assessment, or evidence of wrongdoing. It does not capture registration subsidies or other fees unless separately documented. [S7]
Keep the Ardmore/Del City multi-facility association separate
One 2020 dataset configuration names “Ardmore Regional Park, Del City Ball Park.” It contains one division row, 11 team entries, $4,334 in calculated entry fees, 54 minimum games and 108 modeled officiating assignments. It is excluded from the $1,269,626 direct figure. The label shows an event association, not which games, fees or teams actually belonged to Ardmore rather than Del City. Adding $4,334 yields the broader associated footprint of $1,273,960 and 3,851 team entries, not Ardmore-only revenue. [S7][S8]
Officials and tournament costs: necessary but different ledgers
At least 10,326 modeled games and 20,602 modeled umpire assignments describe minimum labor requirements under Hidden Valley's modeling assumptions. They do not identify the people who officiated, their employment classification, exact wages, or actual payroll remitted in each year. Director association does not establish compensation. A responsible reconciliation requires tournament-specific brackets, official schedules and payments, cancellation/refund logs, and contemporaneous fee schedules. [S7]
4. Three separate money channels must not be mixed
Tournament entry fees: The $1.2696 million Hidden Valley number is calculated fee activity spread across years and venue labels, using the research methodology. It is not a City budget account and cannot be attributed to the YMCA or an individual director based only on a location label. [S7][S8]
Concessions and beverage income: June 2023 minutes report a YMCA concession-sharing arrangement measured as a percentage of gross sales; the rate, audited sales and remittances are not shown. The April 2025 beverage contract's $11,400 per year guaranteed payment spans multiple parks and programs; no defensible allocation to Regional Park alone is available from that Commission item. [S2][S10]
Municipal capital outlay: The July 2025 $1.6236 million contract concerns all eight infields and two playgrounds; this is a capital contract authority, not tournament entry-fee income. The later $1.6805 million amount appears in a January 2026 staff packet and must be checked against executed change orders and invoices. The fiscal-year 2026–27 adopted budget is publicly available for additional account tracing, but it does not by itself supply a reconciled facility-specific lifetime ledger. [S4][S5][S11]
The historical facility profile notes that a digital scoreboard partnership was described as having no cost to local taxpayers. The April 2022 City agenda, however, explicitly proposed a City electricity-related commitment not exceeding $100,000 for eight boards. These two statements cannot be reconciled from the sources here: donation or advertising financing for equipment can coexist with City-financed power infrastructure. The issue is verification of scope and actual payment, not an accusation that the earlier statement was intentionally misleading. [S6][S7]
5. How Public Decisions Shape a Healthy Community-Based Program
| Community outcome | Documented decision or structural condition | Potential effect / what must still be measured |
|---|---|---|
| Affordability | YMCA youth programming was an expressly stated reason for the 2023 field-use decision; Cardinal Park's separate agreement explicitly referenced fee scholarships. | Field access may reduce program costs, but actual local registration prices, discounts, hardship awards and annual changes are required to show affordability at Regional Park. [S2][S3] |
| Local league stability | A multi-year municipal–YMCA relationship and 2023 continuing-use approval are documented. | Predictable seasons can help local leagues plan, yet the specific priority windows, weather displacement rules and cancellation terms must be extracted from the executed Regional Park agreement. [S2] |
| Volunteers | YMCA programs and local baseball operations rely on families and coaches; the YMCA publicly advertises seasonal youth programs. | Program continuity may help volunteers, while volunteer hours, screening, training and turnover remain unknown. [S12] |
| Equitable access | The City maintains public park inventory and has approved designated YMCA facility use. | Whether independent teams, girls softball, school groups, adaptive athletes and other community users receive appropriate access requires booking calendars, fee schedules, scholarship policy and complaint/appeal records. [S1][S2] |
| Transparency | Posted agendas and detailed minutes identify motions and recorded votes; the Parks annual budget is public. | The decision-level record is accessible, but executed copies, amendments, performance reports, facility-specific receipts and spending should be as accessible as authorizations. [S2][S4][S11] |
| Reinvestment | The City authorized $1.6236 million in 2025 for turf and playground surfacing, followed by a proposed 2026 change order. | The improvements could reduce weather cancellations and improve safety, but actual downtime, maintenance costs, warranty compliance and useful life require evidence. [S4][S5] |
| Competition and scheduling | Regional Park includes multiple fields and YMCA has use of a four-field complex; USSSA listings reflect outside event activity over time. | Neither arrangement proves exclusivity. Compare actual local-league schedules to tournament reservations and published neutral selection criteria. [S1][S2][S8] |
| Player development | YMCA publicly lists recreation and competitive youth baseball and softball opportunities. | Evaluating access across skill levels requires participation, progression and attrition measures, not tournament revenue proxies. [S12] |
| Community sustainability | The City, YMCA, event operators and beverage/concession partners operate in overlapping economic channels. | A durable model should show who pays utilities, field labor, insurance and replacements, and where public benefits are reinvested; the available minutes do not supply the full accounting. [S2][S10] |
Analytical distinction: A motion and vote are attributable to the named commissioners recorded above. An administrative recommendation is attributable to Parks staff. Broader structural conditions — nonprofit partnerships, private tournament markets, public infrastructure and volunteer reliance — are not individual misconduct or evidence of a broken system. The merits of a decision require evidence of implementation and results.
6. What the public record proves, what is calculated, and what remains open
Documented public facts: The City lists Regional Park; the City Commission approved two 2023 Regional Park YMCA agreements; a different Cardinal Park agreement has distinct terms; a City-wide beverage contract was approved in April 2025; and a July 2025 capital agreement for eight infields/two playgrounds was approved. A January 2026 packet describes a proposed change order. [S1][S2][S3][S4][S5][S10]
Independent calculations: The September 20 Hidden Valley inventory lists 151 direct division rows, 3,840 team entries, $1,269,626 calculated entry fees, 10,326 minimum games and 20,602 modeled official assignments across three direct Ardmore-linked labels. A separate Ardmore/Del City listing must not be assigned wholly to Ardmore. [S7][S8]
Allegations: This installment makes no allegation of fraud, corruption, illegality, personal enrichment or official neglect. If an outside party supplies an allegation in future research, it will be labeled and corroborated independently before any conclusion is drawn.
Unanswered oversight questions: Which field calendars and written approvals applied to each tournament? Did a particular USSSA director contract with the City, the YMCA, Ardmore Youth Baseball or another owner? What was the approved concession-sharing percentage? What actual operating subsidy, reimbursement, rental fee, field labor or capital cost can be tied to each complex? What was accepted and paid under the turf and scoreboard arrangements? How are residents and outside leagues treated under current policies?
Conclusion supported today: Ardmore has a documented public partnership and documented capital authorization worth studying. The available record supports inquiry into measurable public benefit, not a conclusion of wrongdoing.
7. Records Still Needed — targeted evidence plan
- 2019–2026 executed contracts, amendments and renewal/termination notices for Regional Park North Softball Complex, plus the signed 2023 concession agreement and its predecessor records back to March 2000 where retained; obtain the rate schedule, insurance and financial-reporting clauses.
- 2022 Youth Scoreboards agreement, final minutes, invoices and payment registers, showing whether and how the proposed not-to-exceed $100,000 electrical commitment was used, including sponsorship/advertising rights and ongoing electrical expenses.
- 2025 Forever Lawn/Synturf full agreement, bids/cooperative-purchasing justification, change orders and 2026 approval minutes, progress payments, change logs, close-out acceptance, warranties and capital-fund allocations.
- Field-use calendars and decision files for the North Softball Complex and other diamonds: booking requests, event permits, fees, access priority rules, change notices, denied/conflicting requests, rainouts, and facility condition reports.
- Revenue-and-cost reconciliation by park and fiscal year: YMCA concessions gross-sales reports, City percentage receipts, City concession or rental ledgers, utility and maintenance costs, beverage contract remittances, audits/annual financial statements and park capital expenditures.
- Tournament-specific source records: actual USSSA divisions, fees, confirmed teams, scheduled/completed games, assignment/pay records, collection entities, refunds and gate charges, matched by date, field and responsible contracting party.
- Community outcomes: YMCA and independent league registration rates, need-based discounts, softball/baseball participation, residents vs visitors, volunteer screening/training and parent feedback, privacy-protected where appropriate.
- Ownership and geographic reconciliation: official map or parcel records to resolve whether “Ardmore Youth Baseball” I-35/Veterans venue labels correspond to a specific Regional Park diamond, a separate field, or a historical venue change.
The City publishes agenda, finance and Parks resources useful for pursuing these records. A formal Ardmore Open Records Act request was emailed on October 15, 2026. The requested categories above are now part of the submitted records request; City acknowledgment and production remain pending. [S9][S11]
8. Right of Response
Before making operational judgments, this research invites corrections and source records from the City of Ardmore (City Clerk, Parks and Recreation, Finance and City Commission), Ardmore Family YMCA, Ardmore Youth Baseball or successor community leagues, and tournament operators/directors identified in the relevant event data. Particular requests include venue identification, executed field-use and concession terms, payments, youth registration/scholarship policies, capacity and access, and verified project outcomes.
A formal records request was emailed to City records addresses on October 15, 2026; no substantive response or acknowledgment is documented in the materials reviewed. Any response should be published with source attribution and an update date; factual errors should be corrected transparently.
9. Oklahoma Open Records Act Request — Submission and Public Tracking
Research update: October 15, 2026. Kenneth R. Crawford submitted a formal three-page Oklahoma Open Records Act request to the City of Ardmore by email at 7:48 a.m. on October 15, 2026. The sent-message record identifies recipients records@ardmorecity.org and llinney@ardmorecity.org, with a copy to the requester. The email is addressed to City Clerk Lori Linney and attaches Ardmore Open Records Request 2026-10-15.pdf.
Submission status: Email sent; City receipt, acceptance as a properly routed request, tracking number, fee assessment, and records production not yet confirmed in the supplied record. A sent email does not independently establish receipt or official acceptance.
| Tracking item | Documented information |
|---|---|
| Request date | October 15, 2026 |
| Transmission | Email sent at 7:48 a.m. (as displayed in supplied sent-message record) |
| City recipients | records@ardmorecity.org; llinney@ardmorecity.org |
| City contact | Lori Linney, City Clerk (addressed in submission) |
| Legal basis | Oklahoma Open Records Act, 51 O.S. §§ 24A.1 et seq. |
| Research period | January 1, 2001–October 15, 2026, with limited earlier predecessor agreements where relevant |
| Requested format | Electronic records; phased/rolling production requested |
| City tracking number | Not yet provided or verified |
| City response | Awaiting acknowledgment / routing instructions |
Scope of the submitted records request
- Facility ownership and authority: deeds, leases, site maps, policies and operational control.
- YMCA agreements: executed field-use and concession agreements, amendments, extensions and predecessor contracts.
- Reservations and tournaments: booking calendars, applications, event permits, fees, priority rules and USSSA-related City records.
- Facility revenues: concessions, rental receipts, remittances, sponsorships and beverage-vendor payments.
- Capital improvements: the 2025 $1,623,613.82 turf contract, proposed 2026 $56,919.72 change order, procurement and actual payments.
- Scoreboards and operations: the 2022 Youth Scoreboards arrangements, proposed electrical commitments, utilities and maintenance.
- Governance: adopted minutes, staff memoranda, policies, approvals and accountability documents.
- Community benefit: existing reports on participation, scholarships, access, utilization and program outcomes.
The submission asks the City to confirm the proper route for filing, or forward the request to the appropriate custodian if needed. It requests an acknowledgment and tracking number, advance notice of any proposed charges, and rolling electronic production. The request does not ask the City to create new records or obtain records outside its possession or control.
Correspondence and records-production log
| Date | Event | Status / evidence |
|---|---|---|
| October 15, 2026 | Formal records request and three-page PDF transmitted by email to City records addresses. | Sent email and attached request retained in the research archive. Receipt not yet confirmed. |
| Pending | City acknowledgment, confirmation of submission procedure and assigned reference number. | No City reply included in current research materials. |
| Pending | Fee estimate, phased release, exemptions/redactions or records production. | Will be documented with dates and source records as communications arrive. |
Public documentation note: The signed/submitted request and sent-email evidence are retained in the research archive. A public download link will be added if those documents are published to a stable website address. Future updates will distinguish City statements, actual records produced, researcher analysis, and unresolved questions; personal information protected by law will not be published.
Research commitment: This is an ongoing, evidence-first public-records inquiry. The act of submitting a request is not proof of any irregularity, and the absence of a response at this early stage should not be interpreted as a refusal.
Sources and evidence register
[S1] City of Ardmore — Ardmore Regional Park (municipal location, public amenities, reservations): https://ardmorecity.org/332/Ardmore-Regional-Park
[S2] City of Ardmore — City Commission minutes, June 20, 2023, pp. 12–14 (YMCA concessions and North Softball Complex field-use agreements, votes, historical relationship, lease/renewal descriptions): https://www.ardmorecity.org/AgendaCenter/ViewFile/Item/9944?fileID=6715
[S3] Same June 20, 2023 City Commission minutes, pp. 13–14 (separate YMCA agreement at Cardinal Park and scholarship/utility provisions): https://www.ardmorecity.org/AgendaCenter/ViewFile/Item/9944?fileID=6715
[S4] City of Ardmore — City Commission minutes, July 7, 2025, pp. 4–5 (approved $1,623,613.82 turf/surfacing contract, 8 infields, 2 playgrounds, $1.7 million budget, recorded motion and votes): https://www.ardmorecity.org/AgendaCenter/ViewFile/Item/12522?fileID=7985
[S5] City of Ardmore — City Commission agenda packet, Jan. 20, 2026 (staff's proposed $56,919.72 change order and projected $1,680,533.54 total; agenda is not proof of vote or final spend): https://www.ardmorecity.org/AgendaCenter/ViewFile/Agenda/_01202026-1884?packet=true
[S6] City of Ardmore — City Commission agenda, April 4, 2022 (Youth Scoreboards electrical/sublease item, proposed amount not exceeding $100,000; no outcome inferred from agenda): https://www.ardmorecity.org/AgendaCenter/ViewFile/Agenda/_04042022-1316
[S7] Hidden Valley — Ardmore Regional Park historical research and facility summary (independent public-event reconstruction and methodology; not an official USSSA financial statement): https://www.baseballheaven.net/ardmore-regional-park/
[S8] Hidden Valley — Sept. 20, 2026 Sports Facilities Inventory, internal research workbook titled HVIOG_9-20-2026_Sports_Facilities_Inventory.xlsx, “Facility Master Inventory” tab, venue rows “Ardmore Regional Park,” “Ardmore Youth Baseball,” their joint label, and Ardmore/Del City. Division-row calculations in this article are sums of separate stand-alone configurations, not a claim of unique age divisions. Related statewide methodology: https://www.baseballheaven.net/usssa-team-count-methods/
[S9] City of Ardmore — Agendas and Minutes portal (City Commission, Regional Park Authority and Parks Advisory agendas are separate public boards/records): https://www.ardmorecity.org/AgendaCenter
[S10] City of Ardmore — City Commission minutes, April 7, 2025, pp. 4–5 (five-year $11,400 annual beverage contract for numerous municipal venues; motion and votes): https://www.ardmorecity.org/AgendaCenter/ViewFile/Item/12156?fileID=7878
[S11] City of Ardmore — FY2026–27 annual budget portal (city-level public adopted budget, not a reconciled park operating audit): https://ardmorecity.org/223/Annual-Budget
[S12] Ardmore Family YMCA — published programs and services (publicly advertised youth baseball/softball recreational and competitive programs; not registration/outcome statistics): https://www.ardmorefamilyymca.org/programs-services/
[S13] Research archive — October 15, 2026 Open Records Act submission: three-page formal request titled Ardmore Open Records Request 2026-10-15.pdf and sent email titled Formal Oklahoma Open Records Act Request — Ardmore Regional Park, YMCA Agreements & Youth Sports Facilities (2001–2026), showing 7:48 a.m. transmission to the two City email addresses. These are submission evidence, not a City acknowledgment.
Research footer: Oklahoma’s Fields of Accountability is an independent historical and policy research series. Names, motions and payments in primary records are described according to their evidentiary status. The article is an open research file and can be updated as executed agreements, records responses and community input become available.
Following the money. Following the facilities. Following the decisions. Following the public record.
Publication note: This original article references the existing Hidden Valley Ardmore research; it is not a separate audit, allegation or finding of misconduct. Primary municipal decisions remain distinguishable from the independent historical fee calculations.