Why the City Must Halt the Proposed Sale to
Emerald Youth Foundation

The City of Knoxville’s proposed sale of 12.7 acres of Chilhowee Park to the Emerald Youth Foundation (EYF) raises urgent concerns over appraisal integrity, compliance with city code, transparency, and broader patterns of municipal disinvestment. Based on available evidence, the sale process appears premature, under-documented, and inconsistent with the public interest.

1. Appraisal Problems and Unreliable Pricing

The City’s appraisal, which set the value for 12.7 acres of public parkland, rests on a thin evidentiary basis.

• Thin Evidence: The appraiser relied on only six comparable properties, many of which differ significantly in size, location, and redevelopment potential. No explanation is offered as to why these properties were chosen, nor whether they are representative of the true market for East Knoxville land. Such selective comparables risk undervaluing public property and fall short of the best practices outlined in the Uniform Standards of Professional Appraisal Practice (USPAP).

• Size Curve Issues: Industry guidance notes that large tracts of land cannot simply be valued using smaller residential or commercial lots as comparables. Without proper adjustment curves or demonstration of market relevance, the appraisal produces unreliable pricing.

• Appraiser Qualifications: It remains unclear whether the appraiser is certified in valuing large parcels or redevelopment projects in Knoxville. Demonstrable experience in these specialized areas is critical to ensure accuracy and public trust. Until this is verified, the appraisal cannot be considered a credible basis for transferring public land.

2. Disparate Treatment and Municipal Disinvestment

A broader inequity frames this issue: disparate treatment in how Knoxville invests in parks and infrastructure.

While some neighborhoods have benefited from revitalized parks, upgraded amenities, and robust city support, East Knoxville has endured decades of disinvestment. Such municipal neglect depresses property values, leaving land artificially cheap when the city later seeks to sell it. This cycle of disinvestment followed by undervalued sale not only deprives communities of fair development but also compounds historical inequities.

3. Procedural Failures Under City Code

The City of Knoxville is bound by its own laws. Specifically, Article VII, Sec. 2-722 of the City Code governs the disposal of real property.3 This provision requires:

• Full transparency;

• Documentation of a cost-benefit analysis;

• A competitive process that considers all bids and proposals.

At present, it remains unclear:

• Whether other bidders applied for the Chilhowee Park land;

• Whether the City ever weighed the long-term community benefits of retaining public ownership versus selling to EYF;

• Whether the required cost-benefit analysis was completed at all.

If these procedural steps were not followed, the City is failing its own mandate and the sale cannot be considered lawful or legitimate.

4. Ethical Concerns: Transparency and Accountability

Beyond legality, the sale raises ethical concerns. Public trust depends on transparency in how city officials communicate with private donors, nonprofits, and community stakeholders. Yet the City has released little information about the process or negotiations that shaped this proposed transaction.

Residents deserve access to:

• All communications between city officials and EYF regarding Chilhowee Park;

• Documentation of donor commitments tied to the project;

• All draft and final contracts or memoranda of understanding.

Requests under Tennessee’s open records law will be filed to obtain these materials, and the costs of copying should be waived given that the matter serves the public interest.

5. Supplementary Materials to Be Requested To fully evaluate the Chilhowee sale, the following records must be produced:

• All appraisals of Chilhowee Park land (2020–present);

• All bids or proposals received for the 12.7-acre parcel;

• Communications between city officials, EYF, and private donors related to the sale (2017–present, to include relevant precedent from the Lonsdale Project);

• Cost-benefit analyses prepared under Sec. 2-722;

• Contracts, memoranda of understanding, or commitments of financial support.

The date range of 2017–present is justified: the City’s earlier commitments to the Lonsdale project — including $4 million pledged by the Haslam family during Bill Haslam’s tenure as governor — provide important precedent for how public-private park projects are structured and justified. Comparing those investments with current treatment of Chilhowee Park will help determine whether East Knoxville is being subjected to inequitable or disparate treatment.

Conclusion and Call to Action

Knoxville residents deserve assurance that public land is not being undervalued, that city processes are being faithfully followed, and that community voices are central to decisions shaping public spaces.

This proposed sale should not proceed until:

• An independent reappraisal is conducted by a certified expert in large-tract and redevelopment properties;

• The City publishes its full cost-benefit analysis;

• All bids and proposals are disclosed;

• Communications and contracts are released for public review;

• Equity considerations are addressed, ensuring East Knoxville is not again subjected to systemic disinvestment.

The stewardship of Chilhowee Park must be guided not by expediency, but by fairness, transparency, and accountability to the public.