Real Estate and Urban Planning

1. RICS – CPD
September 24, 2012
The Relationship Between Real Estate and
Urban Planning
• Presenter: Mircea Enache, Architect and Planner,
President of EMI Systems, Inc (Washington) and EMI
Invest, srl (Brasov), Director of the Center of
Excellence in Planning (Bucharest).

2. Program
• The Relationship Between Real Estate and Urban
Planning (15’)
• Trump in New York City: Real Estate, Urbanism,
Design Excellence, Marketing Talent (30’)
COFEE BREAK – 15’
• New Tools for Land-Use Planning in the USA – 30’
• Combining Capital Investments and Land-use
Controls (15’)
• Questions and Answers (15’)

3. The Relationship Between Real
Estate and Urban Planning

4. The Relationship Between Real Estate and
Urban Planning
• Strong link. The twin processes of planning and
property development are inextricably linked — it's
not possible to carry out a development strategy
without an understanding the planning process, and
equally planners need to know how real estate
developers do their job.
• Beyond blind regulation and sheer profit
making. Recently, both planning and real estate
development have had to become aware of their
legal and moral obligations, sustainability issues and
corporate social responsibility and their impact on
the planning and development processes.

5. The British Urban Planning System
• One of the most advanced in the world
• From “Garden Cities of Tomorrow” (Ebenezer
Howard) to Structure Planning of the 70s
• Contemporary British Urban Planning (Enache, 1979)
• Town and Country Planning Act (1947)
• Structure Plans – recommended in 1967 by the
Planning Advisory Group
• Slow to implement, and costly – many were never
completed
• The “no planning” policy of Margaret Thatcher
• Changes under Tony Blair (recouping some of the
losses) – still quite conservative planning

6. Reforming the British Planning System
2001 - a review of the planning system
• It was found to be 'complex, remote, hard to understand
and difficult to access'
• Local plans were deemed to be overly complex, often
inconsistent with regional or national policies, too lengthy,
inflexible in content, and slow and expensive to produce
• Development Control (the process by which decisions are
made on planning applications) was considered slow and
highly variable in speed measured across councils, as well as
being unresponsive to the needs of business/investment
and the community.
• British planning it failed to engage communities, leaving
them ‘disempowered’. The public needed to be more
engaged.

7. Reforming the British Planning System
2004 and 2006 - a second round of reviews
• further action needs to be taken to deliver an
efficient planning system by reducing delays,
addressing unnecessary complexity and increasing
2001 until 2010 - almost continuous change and a
rolling series of new legislation and other reforms
• promotion of an 'urban renaissance' (Urban Task
Force 1999 and 2005)
• combating urban sprawl
• increased participation of the private sector

8. CONTINUED
• past reliance on rigid planning standards stifled
creativity
• promoting the 'compact city' (higher densities), to
foster both sustainability and
• urban quality
• greater attention to urban design, to facilitate
mixed-use/mixed-tenure development and to
foster sustainability
• mixed-use and mixed ownership
• 'urban village' (also sometimes referred to as new
urbanism')
Discussion of Romanian cities’
“masterplans” (PUGs)

9. Trump in New York City:
Real Estate, Urbanism, Design
Excellence, Marketing Talent

10. The History of TRUMP TOWER
1971 eleven-story building at 57 Street and Fifth
Avenue - BONWIT TELLER, property of
GENESCO company
1975 CEO GENESCO – Franklin Jarman
Trump – offers to buy the building
Offer rejected
Trump writes letters every month insisting
on the deal
1978 GENESCO has financial problems
Banks designate a new CEO: John Hanigan
Trump calls Hanigan and they meet after 30
minutes

11. Agreement with GENESCO (“the deal”)
• GENESCO owns BONWIT building, but not the land
• The land is in leasing for another 29 years
• Trump offers to buy the building and the leasing for $25M
• Trump asks for a signed agreement (Letter of Intent), to
get protected from the competition
• Trump approaches Chase Manhattan Bank and asks
for a $25M loan
• The remaining leasing (29 years) is too short for bank
financing (too big a risk)
Trump solution: 2 alternatives
1)Cheap conversion into an office building with street level
retail, cheap rent $125,000 per year) over 29 years (under
rent control conditions) = profit
2)Buy the building, the rent for 29 years and the land under
the building

12. Deal with EQUITABLE LIFE
ASSURANCE SOCIETY
(the owner of the land under the building)
• Trump proposes an equal partnership (50/50)
with Equitable to jointly build a modern tower
• Equitable Life’s alternative is getting the cheap
rent for the remaining 29 years, under the real
estate market picking up
• Equitable Life – skeptical regarding the
feasibility of obtaining the zoning approvals, but
approves the deal

13. The Deal withTIFFANY
Trump intends to buy the air rights of the adjacent building
(TIFFANY), in order to significantly expand the lot.
Walter Hoving (TIFFANY) receives Trump
Trump takes along the scale model of the proposed tower
in two alternatives (made by his architect, Der Scutt)
• A hideous version on the smaller lot (no air rights)
• A spectacular version on the larger lot (with air rights)
Trump offers $5M for the air rights (unused by TIFFANY),
solution which assures the presence of TIFFANY
Hoving agrees. Problem – he will be on vacation for one
month
Real estate is growing fast, Philip Morris buys a lot more
expensively the air rights of Grand Central, etc.
Luckily, Hoving keeps his word when back from vacation

14. The Battle for 4,000 sq. ft.
Small lot adjacent to Trump’s lot, very useful for the 30 ft
retreat required by zoning
The lot is leased by Leonard Kandell from BONWIT. The
remaining leasing period is 20 years, and comes with
rezoning restrictions
Kandell absolutely refuses to sell
Trump discovers a clause in the air rights contract, allowing
TIFFANY to buy Kandell’s lot
Trump buys this right from TIFFANY and goes to Kandell
Kandell maintains that TIFFANY’s right is not transferrable,
but Trump threatens with suing in court
In 20 minutes they cut a deal:
• Kandell extends the leasing from 20 to 100 years
• Kandell rewrites the leasing contract and eliminates the
rezoning restrictions

15. The Deal with GENESCO (the battle continues)
Negotiations with GENESCO – Dec 1978
Negotiations leaked - GENESCO is bombarded with offers
The Latter of Intent has limited value: possibly delaying the
deal through suing in court
January 1978 – a New York Times reporter asks for selling
negotiations confirmation. Trump confirms.
The best BONWIT employees panic and look for work
elsewhere.
GENESCO needs cash badly, approves theTrump deal, but
asks for 50% upfront ($12,5 M)
Trump’s lawyers do not agree – huge risk
Trump accepts but requires closing the deal (going to
settlement) in 2 months rather than 6 months

16. Focusing on Design
Trump asks his architect (Der Scutt) to immediately start
the tower design
Goal: to maximize the size of Trump Tower, to make it
the most fantastic building in New York City. Maximum
FAR (floor area ratio) for the lot: 21,6
Without air rights and without Kandell’s 4,000 sq.ft. lot,
the maximum FAR is 8,5 (20 stories of 10,000 sq.ft. each
or 40 stories of 5,000 sq.ft. each)
Trump chooses the higher rise for two reasons:
- Superb views in all four directions
- Fewer apartments per story, and consequently more
expensive per sq.ft.

17. The Battle for Zoning Approvals
Trump tries to exploit every bonus (FAR increase) legally
available to developers in New York City:
• Bonus for the residential function (the rationale is that
offices generate intense auto traffic)
• Bonus for providing public space at street level, including a
lot crossing
• Bonus for commercial facilities more extensive than
required by zoning
• Bonus for creating a green, planted space at street level
Discussion with Der Scutt about a possible multi-story atrium
with shops (a small mall)
Even without financial success, the commercial atrium would
be useful (by allowing several additional residential stories to
the tower)
Trump tests several store chains and the reaction is positive

18. The Trump Touch and the Trump
Philosophy
• Be distinctive; add “sizzle” to your property
• Give your customers the ultimate in
perceived quality
• Understand your buyers’ and tenants’
lifestyles
• Know what your customers will pay extra for
and what they won’t

19. The Building Architecture (Trump Tower)
Der Scutt produces 30-40 architectural solutions, while
Trump selects the most valuable features of each
• The glass box model is too boring
• The three exterior elevators model consumes too much
useful space
• Der prooses a system of recessed terrases which is
immediately agreed by Trump and his wife, Ivana
• The top of the building has a jigsaw pattern (a total of 28
sides of the building envelope) - amore expensive
solution, but with a unique and spectacular architecture
• Each apartment has at least two views, which increases
its price. With Trump, esthetics and profit go hand-in-
hand.

24. Project Approval by the City Hall
Trump fights for each zoning variance needed
He uses logic to make his case, for example: the North-South
crossing required by zoning is replaced with a East-West
crossing, which places the building access on Fifth Avenue
In December 1978, the City Hall Planning Commission denies
Trump any FAR bonus because the tower results too big and
does not integrate with the site
In 1979 Trump shows up in the City Hall with two scale
models:
• A “legal” solution, which does not require any zoning
changes, a horrible 80-story prism which cantilevers over the
next building (TIFFANY)
• His solution, which requires zoning variances and the use
of all possible FAR bonuses allowed by the law
The members of the Planning Commission are terrified.

25. Opportunities for Zoning Changes
BONWIT changes owner. It is bought by ALLIED STORE
CORPORATION.
ALLIED experiences financial troubles. Trump offers ALLIED a
deal: a 55,000 sq.ft. commercial space on 57 Street, directly
linked to the tower atrium, which allows them to remain in mid-
Manhattan. ALLIED agrees to pay Trump $3M rent per year,
plus un percentage of their profit.
THE TRUMP DEAL. He bought the long lease and the BONWIT
building with $25M (at an annual mortgage cost of $2.5M and
now receives $3M per year from BONWIT for the space in
Trump Tower he rented them. He gets a net profit of $500,000
per year and the land for free, before even starting building the
tower. Moreover, it strengthens his chance of getting the FAR
bonuses and zoning approvals from the City Hall, which wants
to keep the BONWIT chain in Manhattan.

26. Public Opinion and the Press
Neighborhood associations try to block the project.
Trump faced with the risk of 6-12 months delays in getting the
planning and zoning approvals.
In June 1979 Trump invites Ada Louise Huxtable, very
influential architectural critic at New York Times, to see the
Trump Tower scale model.
In her New York Times article, Huxtable, stout enemy of
skyscrapers, blames the City Hall for not being able to control
developers, which use every trick possible to maximize their
FAR. Zoning regulations are too weak, she says.
However, she has words of praise for the Trump Tower project
which exhibits excellence in design, a “dramatically
handsome structure”, “extraordinary public amenities” etc.
Practically, the excellence in design brings Trump all the
requested approvals.

27. Why Trump Building Projects Are
Always on Time and Under Budget
Trump advises developers to:
• Manage contractors and control costs
• Be your own general contractor when
possible
• Create incentives for being early rather
than having penalties for being late
• Be fanatical about details
• Motivate people

28. Trump Tower Construction
1980 – Chase Manhattan Bank finances construction
HRH Construction is the general contractor
Total budget (land, construction, interest, advertisement and
promotion): $200M
Barbara Res (33 years old) supervises all activities
Ivana Trump involves herself in interior design decisions, choice of
materials etc.
When demolishing the BONWIT building, Trump pledges two Art
Deco basso-reliefs to the Metropolitan Museum of Art, but cannot
save them because of their weight.
Public scandal follows, involving the press, citizen associations etc.
Trump regrets his decision, but realizes that even getting bad press
is better than being ignored by press. Comments like “demolishing
two Art Deco basso-reliefs to build one of the most luxurious
building in the world” bring Trump a flood of clients and a major
increase in price per sq.ft.

32. Glamour and Glitz of the Public Space
Major success factor, obtained through design excellence
and fanatical attention to detail.
Example: the atrium marble (Breccia Perniche), a rare marble
in rose shades, selected by Donald and Ivana Trump from
hundreds of samples. Visits to the marble quarry in Italy,
marking the acceptable marble blocks, rejecting unacceptable
transports, reserving the entire quarry production for Trump
Tower etc.
The entire atrium is glamorous: polished brass railings, huge
areas of reflecting glass, 80-ft. high water fall ($2M), etc.
The tower entrance on Fifth Avenue has a 30ft opening rather
than the 15 ft required by zoning.
Apartments start on the 30th floor and offer views in four
directions: Central Park, the Statue of Liberty, Hudson River
and East River. They have panoramic, floor to ceiling
windows.

35. Trump Marketing Strategies
• How selling the “sizzle” sells the product
(how to play up your location)
• Showing the property: the aesthetics
must draw people in
• Use dazzling presentations
• Advertising strategies (video and
computer-based presentations, literature,
art work and models)
• Use intelligent promotions
• Marketing to home buyers and renters

37. Real Estate Promotion: The Aura de
Uniqueness of Trump Tower
Excellence in design, materials, execution, location,
advertisement, the right moment and timing and sheer
luck provide an aura of uniqueness and magic.
Trump Tower beats the competition:
• Onassis’ Olympic Tower (51st Street & Fifth Avenue)
• Museum Tower (53rd Street & Fifth Avenue), next to
MOMA
• His prices are 30% higher per sq.ft.
Trump and family inhabit one of the three triplex
penthouses (12,000 sq.ft). Then he adds another
apartment to his penthouse.

39. Trump Sells Dreams, Fantasy, Uniqueness
• Trump Tower sold as “event”
• Highest price, with no rebate for celebrities like:
Johnnie
Carson, Steven Spielberg, Paul Anka, Liberace
• Special attraction: the first residential condominium
in Manhattan (most residences were “cooperative”)
• The Prince Charles and Lady Diana rumour
• Marketing strategy: “hard to get” – actually worked.
They raised the price 12 times.
• Clients: rich Arabs, French (in 1981), Wall Street,
South Americans, Japanese
The commercial atrium-ul – a great financial success:
Cartier, Buccellati, Harry Winston, Charles Jourdain,
Martha, Asprey etc.
Exceptionally favorable press (New York Times).

40. Center of Excellence inCenter of Excellence in
Planning (CEP)Planning (CEP) –– inin
cooperation withcooperation with
UAUIM, BucharestUAUIM, Bucharest
•• Education and researchEducation and research
•• International presence and cooperationInternational presence and cooperation
•• Regional hub (Eastern Europe and theRegional hub (Eastern Europe and the
Balkans)Balkans)
•• ValueValue--added and creative/innovativeadded and creative/innovative
approach to make Romanian citiesapproach to make Romanian cities
competitivecompetitive
•• Emphasis on young researchers andEmphasis on young researchers and
specialistsspecialists

41. Advanced Studies in Urbanism and Real
Estate Development (ASURED)
• Post graduate program UAUIM and CEP, with
RICS accreditation
• A two-year program, part time, distance
learning, 1800 hours of study
• Faculty from Richmond (Virginia), Vienna,
Madrid, Sofia and Bucharest
• Students from the region (Romania, Bulgaria,
Kosovo, Serbia, Moldova)

42. ASURED Main Goals
– cooperation between planners and developers
– expanding the job opportunities of young
graduates (international planning and real
estate market, academia)
– RICS certification and strengthening RICS
Romania
– link between ASURED and the research axis of
CEP (joint applied research, strong presence in
Europe and US, marketing and promoting
Romanian cities internationally)

43. New Tools
for Urban
Land-Use
Planning in
the U.S.
• Land-Use Controls
• The Limitations of Zoning
• Making Zoning More Flexible
• Bonus or Incentive Zoning
• Transfer of Development Rights (TDR)
• Inclusionary Zoning
• Planning Unit Development (PUD)
• Cluster Zoning
• Performance Zoning
• Development Agreements
• Form-based Zoning and New Urbanism

44. Land-Use Controls
• Legal Base
- Exercise of police power (no compensation)
- Exercise of eminent domain (with compensation)
• Subdivision Regulation
- Streets, lot lines, easements for utilities
- Land dedications (schools, recreations, facilities)
- Compatible with the municipal Master Plan
• Zoning Ordinances
- Site layout (lot area, depth, setbacks)
- Structure characteristics (FAR, height, stories)
- Uses
- Procedural matters (approval, appeal)

45. The Limitations of Zoning
• Property owners have strong motivation to try to change the
zoning:
– litigation (charge of inconsistency in zoning or “taking” clause)
– building a coalition of forces to lobby for zoning change
– confrontational approach taken by the developer (fiscal impact
analysis and alternative solutions
• If a community is hungry for jobs and additions to its tax base, but
does not show flexibility, potential investors will invest their
capital in other community
• Compromise – the municipal legislative body amends the zoning
ordinance
• If the developer is successful in obtaining the rezoning, he will
make a large sum of money even before construction begins
• Municipalities have a strong bargaining position because they
zone substantial amounts of land in economically unrealistic
categories (“land reserves”)

46. Making Zoning More Flexible
• Zoning = crude instrument: it prescribes what cannot be
done, but it cannot make anything happen
• Its rigidity may lead to less than optimal results
• On the other hand, if every lot is developed to full
intensity, the congestion, traffic and noise may be
overwhelming
• “Zoning saturation” studies (New York would have 30
million inhabitants, instead of 7-8 millions)
• Zoning severely limits the freedom of the architect and
lower the quality of urban design
• Zoning produces a sterile environment through an
excessive separation of uses (Jane Jacobs criticized the
lack of variety of uses) – see “new urbanism”
• Example: New York (Manhattan) and manufacturing
zoning, now gentrified (SoHo, Tribeca) because zoning
regulations were not enforced

47. Bonus or Incentive Zoning
• Increased residential densities allowed if some
units are earmarked for lo- and moderate-
income tenants
• The developer gets the scale economies of
denser development
• In office development, city halls allow additional
height or stories if the developer will provide
certain amenities at ground level (a plaza, a
direct entrance to a metro station, a “vest-
pocket” park or sitting area etc)
• See Trump Tower bonuses obtained by Trump

48. Transfer of Development Rights (TDR)
• The goal of transfer of development rights (TDR) is to
concentrate development in areas where it is wanted and to
restrict it in areas where it is not.
• A sending area and a receiving area
• Property owners in sending areas who do not develop their
properties to the full extent permitted by the law may sell
their unused rights to property owners in receiving areas
• Potential benefits: preserve open space, limit development
in ecologically fragile areas, historic preservation etc.
• Can this not be done with conventional zoning? Opposition
and litigation
• When property owners sell their development rights, they
can no longer redevelop at higher densities
• For the municipality, the technique, like zoning itself, is
essentially costless
• It might be susceptible to abuse

49. Inclusionary Zoning
• In inclusionary zoning, developers who build
more than a specified number of units must
include a certain percentage of units for low-
and moderate-income households
• It differs from the incentive or bonus approach
in that the inclusion of units for low- and
moderate-income households is not
discretionary
• It shifts some of the costs of housing such
households to the developer, who shifts some
or all of it to the buyers or renters

50. Planning Unit Development (PUD)
• Planning Unit Development (PUD) has been widely used in
the U.S. in the last decades
• Under a conventional zoning ordinance, the law provides
that a property owner with a minimum number of acres
(e.g. 20), has the option of applying to develop his
holdings as a PUD
• A different set of controls applies (density and uses
permitted)
• Residential, commercial or mixed use PUDs
• For the urban designer, PUDs can offer vastly more room
for creative and innovative design
• Mixing residential uses with commercial uses tends to
make the area more active in the evenings and on
weekends
• Some disadvantages, e.g. opposition from adjacent
property owners (surprise neighbors…)

51. Cluster Zoning
• Another flexible technique
• Cluster ordinances generally apply to residential
development, permit the building of houses on
smaller lots
• The saved space must be used for community
purposes (open area, club etc)
• Very popular with planners: preserves open space
and reduces development costs
• Public suspicion – people are afraid that sooner or
later the open blocks will be filled in with housing
• In reality, the open space is easily protected with
proper legal documents

52. Performance Zoning
• Performance zoning is relatively new and not in
widespread use
• Conventional zoning results in fewer uses being permitted
in any single district, leading to frequent requests for
zoning amendments
• Performance zoning codes stipulate what may or may not
be done in terms of end results instead of giving detailed
regulations on the exact form of development
• Achieving the same goals as conventional zoning but in a
more flexible manner
• Example: Largo, Florida
– Five residential categories – limits on floor area ratio (FAR)
and the percentage of the site that can be under impervious
cover, no limitations on the types of housing, setbacks and
building height
– Four separate commercial zones (FAR and impervious cover)
– Downtown: FAR of 0.90 and an impervious cover of 100%

53. Development Agreements
• New land-use tool introduced in California
• Enabling legislation that permits municipal
governments to enter “development agreements”
• They bypass the existing zoning, but they must be in
conformity with the comprehensive plan
• The contract stipulates what the developer may do or
is required to do
• The municipality is legally bound by the contract, so
the developer is sure that zoning and other controls
will not change during the development process
• Example: Santa Monica, California
– The developer was allowed to build above the 45-foot
height limit specified in the zoning ordinance and to
include some uses not permitted by zoning
– The City got some off-site low-income housing, a small
on-site park and a child-care center

54. Exactions
• Numerous communities have resorted to exactions
(charges) before giving permission to develop
• In some cases, they are required only if there is to be
a rezoning or zoning variance
• In other case, exactions are charged for development
within the existing zoning law
• In some cases, the exaction may be for a closely
related cost, e.g. nearby road construction, or school
or park construction for the neighborhood
• Others are more convoluted, e.g. San Francisco
– Since 1981, builders of office structures of over
50,000sq.ft. of floor space must earn housing credits by
either by building new units themselves or contributing
funds to housing rehabilitation or affordable housing
projects

55. Form-based Zoning and New Urbanism
• The most recent major development in zoning
• Form-based zoning are more flexible than traditional
zoning in some ways, and less flexible in other ways
• It places the emphasis on the physical form of the
development – on what the area in question will actually
look like
• It is more flexible about permitted uses and it is
consistent with neo-traditional design (Andres Duany –
“new urbanism”)
• The form-based zoning defines areas on the map and then
specifies a number of design criteria that the developer
must meet in each zone
• It shifts a considerable amount of the decision from the
individual builder or developer to the planner or urban
designer

56. Form-based Zoning Features
• The form-based zoning code is very pictorial (“this is what
it should look like”)
• It specifies maximum heights, but also minimum heights,
in order to achieve a compact, walkable environment
(neo-traditional concept)
• It specifies setbacks, but not minimum setbacks, rather
exact setbacks, or no setbacks at all
• It specifies placement of entrances, details about doors,
windows and courtyards, and sometimes even the
materials used
• It includes specifications about sidewalk widths, radius of
curbs, planting and trees, down to acceptable species
• The form-based zoning code is much more restrictive and
directive that the traditional code
• Defficiency: a relatively static tool, risk of urban cliché

57. Combining Capital Investments and
Land-use Controls
• Combining the two main land-use controls
• Forces beyond local control
• Higher levels of land-use control
• Why is higher level control necessary?

58. Combining the Two Main Land-use
Controls
• Enlightened communities in the U.S. combine Capital
Investments and Land-Use Controls , so that they
enforce each other
• Example: Westchester County, New York
• The city of White Plains and the town of Harrison
received a massive collection of corporate headquarters
and other office development (thousands of jobs and
hundreds of millions of dollars)
• Basic preconditions: good location within the New York
Metropolitan Area (possible to capture firms moving
out of New York City but remaining in the metropolitan
area, as well as firms moving into the metropolitan area
but avoiding the high costs of a Manhattan location)

59. CONTINUED
• Capital Investment
• Including a proposed White Plains Arterial bypass into the
design for the Interstate Highway System – 90% of the
cost of building it came from the federal government
• Federal funds used to create demand
• Land-Use Controls
• To produce a desirable result and prevent land uses from
blocking desirable development
• Strategy - zoning to permit office development, requiring
large minimum sites
• Retailing where there is good highway access and largely
populated areas
• Strip commercial development (eating up frontage and
creating an unattractive environment) was simply
prohibited

60. Forces Beyond Local Control
• Other actors in the picture:
– state highway departments
– state legislators (state facilities)
– governors
– major corporations moving into or out of the area
– institutions (major universities)
• Decisions made in corporate boardrooms can have
major effects on the pattern of development
• State and municipal governments make decisions
about land use and public capital investment with an
eye to their effects upon attracting industrial and
commercial investment (including negotiations with
those firms)

61. Higher Levels of Land-use Control
• State governments and the federal government
– some control over land-use decisions that
were formally left up to local governments
• It was called “the quiet revolution”
• It provides some degree of state of regional
participation in the major decisions that affect
the use of the increasingly limited supply of land
• Higher-level controls - where there is a clear
public interest beyond the borders of the single
community
• Usually coming from environmental concerns

62. Why is Higher Level Control Necessary?
1. The issue of externalities
E.g. If a community grants a rezoning that enables a
shopping center development on a wetland, the
community gains:
- fiscal gains of the development
- employment gains
- some of the increase in land values
The unfavorable effects are felt outside the community
2. The technical complexity
Most local governments do not have the time and
expertise to do the data gathering and analysis required
for good decision making

63. QUESTIONS AND ANSWERS