An application for relocation of the Phoenix Coyotes to Hamilton submitted to the National Hockey League late Monday night fills all the required criteria, says the application's writer.

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Jim Balsillie has enlisted former CFL commissioner Tom Wright (file photo) to help him prepare his application to relocate the Phoenix Coyotes to Hamilton.

Photograph by : Reuters

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"All I can tell you is the submission we've made to the NHL is fully in compliance with their bylaws and rules and regulations," Tom Wright told reporters during a media conference call Tuesday afternoon. "It very strongly speaks for itself."

Wright, the former commissioner of the Canadian Football League was hired and retained by prospective owner Jim Balsillie's group to prepare the relocation document. He said he is not part of PSE Sports & Entertainment.

NHL deputy commissioner Bill Daly confirmed that the league has received the application.

"Yes, I can confirm we received an application to relocate the franchise yesterday," Daly wrote in an email to Canwest News Service. "We will not be commenting on the submission, or our response to the submission."

Information gathered for the application was provided by current Coyotes owner Jerry Moyes.

"We had access to all of the financial records of the Coyotes through Mr. Moyes. We were able to look at, not only the most recent financials, but financials throughout its 13-year history. When you look at those, they're quite revealing. In 13 seasons, the club has never posted a profit. It has experienced cumulative EBITDA (earnings before interest, taxes, depreciation and amortization) losses in excess of $316 million. . . . Those numbers are factual numbers that the Coyotes have provided," said Wright.

"The club is not financially viable and the prospect for the club to become financially viable is not present either," he added.

Wright indicated looking at the history of the franchise led him to the conclusion that hockey cannot survive in Phoenix.

"And so (we conclude that through) ticket and attendance records and season-ticket performance, these kind of things, and avidity scores. The club has done its own financial projections and despite, incredibly from where I sit, aggressive and optimistic assumptions . . . even then over the next five years the club is projected to lose in excess of $40 million."

"They're audited financial numbers so their veracity is quite strong."

A Canadian market research organization was additionally hired to conduct surveys and fact finding in both Phoenix and Hamilton.

Bill Walker, a spokesman for Balsillie, indicated the southern Ontario market is ripe for hockey.

"I can tell you that Mr. Balsillie's view is that the team in Hamilton will be an immediate success. It will be sold out or near sold out, and recognize that we've filled the equivalent of seven NHL_arenas with sign-ups on makeitseven.ca, and that's in less than a month. I think the market share speaks for itself," said Walker.

"We know it's a large market, we know hockey is by far and away the No. 1 sport," added Wright. "There's a demonstrated interest in the fans that has been documented through market research through the makeitseven.ca sign-ups, through the 2007 submission of over $11 million worth of ticket deposits in a week or so. We know that the club will operate in a facility that will comply with the NHL's own facility standards. We know that the City of Hamilton has pledged its support. So when you put all of those factors into play . . . there's every indication that the team will be profitable, right from the get-go."

The NHL has opposed the bankruptcy filing of Moyes, and commissioner Gary Bettman said the league does not want to move the team out of Arizona. The sides are embroiled in a legal battle in a U.S. bankruptcy court, with a ruling on whether the team can be sold or moved coming as soon as June 9.

As well, lawyers for the league and Moyes will be presenting written arguments to the court debating whether the Coyotes can be moved as part of a sale. The two sides have been given a Friday deadline by the court.

If the sale is allowed to go ahead, an auction will be held and Balsillie will be a bidder.

Balsillie has pledged to pay $212.5 million US for the team on the condition he can move the team into Copps Coliseum in Hamilton. He said he will also contribute some money toward a possible $150 million Cdn upgrade of the 24-year-old arena.

Walker said early reaction suggests both the Ontario and federal governments would be willing to help support the arena renovation.