• 1-800-123-789
  • info@webriti.com

Category ArchiveResearch

City Set for 33-Year High in New Office Supply Through 2019: C&W

Manhattan is set to see more new office supply come online over the next two years than at any point since the mid-1980s—a dynamic that will bolster the city’s aging office stock but could hold asking rents in check and keep landlord concessions at historic highs, according to Cushman & Wakefield.

Led by sprawling Far West Side megaprojects like Hudson Yards and Manhattan West, the 12.6 million square feet of new office construction due to hit the market over the course of 2018 and 2019 is the most of any two-year period since 1985 to 1986, the brokerage said in a press briefing today overviewing the state of the city’s office market.

While 7.3 million square feet of that space has already been preleased, it is part of an enormous 22.1-million-square-foot influx in new office supply set to arrive in Manhattan over the next five years—13.7 million square feet of which is still available for lease, C&W said. That influx is already placing downward pressure on asking rents for the city’s existing office stock and is expected to keep concessions at “historical high levels,” according to the brokerage.

Richard Persichetti, C&W’s vice president of research for the tri-state region, said that while the new construction is a positive considering the city’s “aging office stock,” it will exacerbate a dynamic that has seen “more tenant improvement allowances than ever before” and could cause a hike in vacancy rates as new space is delivered. Manhattan’s overall office vacancy rate dropped 0.4 percent to 8.9 percent at the end of 2017—”its lowest level in 18 months,” he noted.

New office construction is also commanding a 27.5 percent premium over existing Class A space, according to the C&W report, with the new development consequently driving down rents for the city’s existing office supply. Overall office asking rents in Manhattan fell 0.8 percent in 2017 to $72.25 per square foot—though Persichetti said rents should be “flat to increasing” in 2018 as the new, “higher-priced space” comes online.

In total, Manhattan saw 30.5 million square feet of new leasing activity last year, which was up 16 percent from 2016. Midtown office leasing was up 10.4 percent to 19.7 million square feet, while the Downtown market saw a 63.6 percent jump to 5.8 million square feet. The supply-constrained Midtown South saw a 2.1 percent increase in new leasing activity to 5 million square feet.

Leasing activity was characterized by a sizable uptick in the volume of major, 100,000-plus-square-foot deals; the 56 such leases signed last year were the most on record, according to C&W, and accounted for 40 percent of all Manhattan leasing activity—with 22 of those deals for 250,000 square feet or more.

The financial sector, which saw employment levels in the city rise to a 16-year high in 2017, drove much of the new leasing activity; financial industry tenants leased 5.5 million square feet of space last year, up 60 percent from 2016, the brokerage said. The technology, advertising, media and information (TAMI) sector, meanwhile, softened in terms of employment—losing more than 9,000 jobs through the first 11 months of the year—but still saw a 12 percent increase in leasing activity to 4.3 million square feet, according to C&W.


Source: commercial

NYC’s Retail Chains Feel Headwinds Despite Growing Presence: Report

Though national retail chains continued to strengthen their presence in New York City this year, most of that growth came from food and mobile phone stores like Dunkin’ Donuts and MetroPCS while apparel and electronics retailers continued to experience “significant contractions,” according to the Center for an Urban Future’s (CUF) annual “State of the Chains” report released today.

The 296 chain retailers tracked by the report grew their footprint to a total of 7,317 stores across the city in 2017, up nearly 2 percent from 7,223 stores last year. While that constitutes the ninth consecutive year of a net increase in the number of national chains in New York City, the CUF noted that the growth has been “limited to a relatively small number of retailers”—with more chains than ever feeling the market headwinds that have battered the brick-and-mortar retail sector this year.

Coffee-and-donut behemoth Dunkin’ Donuts continues to dominate the CUF’s ranking of national retailers with a presence in New York, topping the list for a ninth consecutive year and growing its footprint to 612 locations in the city from 596 stores last year. Prepaid wireless provider MetroPCS, fueled by its 2013 merger with T-Mobile, leaped Subway to become the city’s second-largest chain retailer with 445 stores across the five boroughs—an increase of 119 locations from 2016.

But while those companies joined the likes of Crumbs Bake Shop—which has reestablished itself at 22 locations after experiencing financial troubles that forced major closures in 2014—and Pret a Manger among chains that have expanded in New York in 2017, the CUF found more worrying trends across the industry at large. One-fifth of the city’s national retailers have closed stores in the past year (compared with one-seventh in 2016), while only one in seven chains tracked by the CUF actually grew their presence in 2017—the smallest share since the public policy think tank launched the “State of the Chains” report a decade ago

“Every single year we’ve done this [report], the number of chains stores in New York City has gone up, but I think this year we’re starting to see some new challenges,” Jonathan Bowles, the CUF’s executive director, told Commercial Observer.

Bowles noted that while Dunkin’ Donuts and MetroPCS together accounted for 135 new stores across the city in the past year, the other 294 national chains tracked by the report experienced a combined net loss of 41 retail locations across the five boroughs in 2017—statistics that depict “much more of a mixed picture for national retail in New York than has been in the past.”

Food-related chains have thrived over the last decade, alone responsible for more than 40 percent of the growth in national retailer locations in the city over the past 10 years, according to the CUF. The number of coffee chains like Dunkin’ Donuts and Starbucks have grown by 65 percent over the past decade, while fast-casual dining chains like Pret a Manger and Chipotle have more than doubled their presence in that time and fast-food restaurants like McDonald’s have grown 14 percent.

But the news has not been so good for retailers that “compete most directly with online outlets,” the report said, such as those in apparel, footwear, office supplies and electronics. Electronics retailers, in particular, have experienced the biggest drop of any national retailer category—with factors like RadioShack’s bankruptcy meaning there are now fewer than half as many electronics chain locations in New York than there were in 2008 (53 stores today, compared to 144 in 2008).

That dynamic hasn’t extended to mobile phone service chains like MetroPCS and T-Mobile, which in 2017 have surpassed clothing stores as the second-largest national retail chain category in the city, behind fast-food restaurants. Cell phone chains “have dominated the consumer electronics market in the decade since the iPhone was first released” in 2007, the CUF said, having grown to 854 stores across New York City from 233 locations in 2008.

Drugstore chains like CVS, Rite Aid, Walgreens and Duane Reade have struggled in comparison to recent years, losing a combined 53 locations across the city. Chain pharmacies now have a total of 558 locations across the city, up only 1 percent from their number in 2008, the CUF said—attributing the contraction in part to Duane Reade and Walgreens consolidating their locations since merging in 2010, as well as their closing of 600 stores nationwide ahead of a $4.38 billion acquisition of a portfolio of stores from Rite Aid.

Referring to the lukewarm environment for national chain retailers in New York City at large, Bowles cited “the combination of some of the highest rents in America and declining sales because of online competition.”

“A lot of retailers’ profit margins were already slim, and then you add in losses because of online shopping, and it’s not a surprise that a lot of these merchandise retailers are cutting back,” he said—adding that food establishments like Dunkin’ Donuts and Chipotle “aren’t facing that kind of online competition.”

While Manhattan continues to dominate the market among national retail chains with 2,734 locations, Brooklyn has seen the largest increase among New York City boroughs in the number of new chain locations in 2017—adding 47 new stores for a total of 1,587 locations, a 3.1 percent increase from last year.

After Dunkin’ Donuts (612 stores) MetroPCS (445) and Subway (433), the top 10 national retail chains with the most locations in the city are Starbucks (317), T-Mobile (236), Baskin-Robbins (221), McDonald’s (215), Duane Reade/Walgreens (260), Rite Aid (179) and CVS (149).


Source: commercial

Construction Starts in the Bronx Projected to Top $2B—Again

The Bronx is still burning.

Led by strong housing development, the value of construction starts in the Bronx is expected to be more than $2 billion for the third consecutive year, according to a just-released New York Building Congress Bronx study of Dodge Data & Analytics data covering the first nine months of 2017.

The Building Congress forecasts that about $2.3 billion worth in projects will have commenced construction this year in the Boogie Down, roughly the same amount as in 2016, and slightly outperforming 2015’s $2.2 billion.

Projects that started this year in the borough by September were collectively worth $1.7 billion, according to the analysis. (New York City overall saw around $31.2 billion of construction project starts through the first three quarters of 2017.)

The Bronx has seen increasing interest from developers over the last 10 years in response to the demand for more affordable housing citywide as well as the availability and affordability of the land in the borough.

“The Bronx is experiencing positive momentum and benefitting from continued strong investment from both the public and private sectors,” Building Congress President and Chief Executive Officer Carlo Scissura said in a prepared statement. “With the value of annual construction starts more than doubling since the beginning of this decade, it’s obvious that the development community now views the Bronx in a whole new light.  And I would be surprised if that percentage doesn’t continue to rise in the coming years.”

As of September, the top costliest developments in the Bronx this year are a $232 million project to replace Unionport Bridge and a $133 million 12-story, 305-unit apartment building at 443 East 162nd Street in Melrose, which is being developed by New York City’s Department of Housing Preservation and Development, the Women’s Housing and Economic Development Corp. and BFC Partners

Housing account for the largest asset class—53 percent—for which new projects began construction through the first three quarters of 2017 in the Bronx, according to the report. That was followed by public works at 20 percent, institutions (schools and health care facilities etc.) at 15 percent and commercial properties with 11 percent.

“The Bronx possesses the most opportunities for new residential development, and the ability to produce new housing for residents at all income levels,” Scissura said. “As the de Blasio administration further ramps up its affordable housing program and as private developers increasingly look to the north, the future looks bright for the Bronx.”

Excluding the final quarter, the Bronx saw 3,190 residential units begin construction in 2017. The report indicates that the total is on track to outperform last year’s 3,918 units and 2015’s 4,240 units, which was the most in the last decade.

“The Bronx has land, which the other boroughs don’t,” Louis Coletti, the president and CEO of the contractor association umbrella Building Trades Employers’ Association told Commercial Observer. “And the land is obviously less costly than in Manhattan or Brooklyn.”

Regarding the future of development projects in the Bronx, Coletti added: “The only thing that could impede the growth of the Bronx is the natural economics of real estate—if interest rates start to get too high and people decide they aren’t going to borrow money or if [the economy] starts to slow down. Then you will see things slow down in the Bronx.”


Source: commercial

After Tepid Growth, Brooklyn Hotel Room Rates Spike

The Manhattan hotel market—one of the priciest hospitality markets in the country—has been strong this year, with hoteliers selling almost nine out of 10 rooms nightly for the first 11 months of this year. But that demand has not amounted to an increase in average daily rates, or ADR, according to new research from STR, a hotel data and analytics specialist.

Manhattan hoteliers have cut nightly room rates this year by 1.6 percent from 2016, to $269.45 (although the room rate is still higher than in any of the 25 largest markets in the U.S. tracked by STR). That is a continuation of the decline in room rates since 2014’s high of $292.46.

In nearby Brooklyn, however, room rates shot up a considerable 4.1 percent to $182.13 year-over-year, as supply surged 21.1 percent, occupancy rose 4.2 percent to 81.5 percent and the number of hotels rose from 61 to 71 today.

Manhattan “is getting very expensive with ADR and development costs and I think a lot of people are looking outside, right across the river,” said Jan Freitag, a senior vice president of lodging insights for STR. “There is very, very strong supply growth and even stronger demand.”

Brooklyn’s 4.1 percent ADR uptick is double the U.S. average percent change to date, and the year-over-year increase is much greater than the borough has seen over the last couple of years. Between 2015 and 2016, the ADR grew by 1.4 percent, and the year prior, it increased 1.3 percent.

Today, Brooklyn hoteliers have more “conviction” to increase their pricing, Freitag said. Brooklyn is now a destination in its own right, and between its proximity to Manhattan and its new product—with sweet amenities—hoteliers have reasons to justify higher prices. To stay at the William Vale Hotel in Williamsburg for one night in mid-January, for example, costs $279 plus taxes, the hotel website indicates.

“Brooklyn is super hot,” Freitag said. “Developers like it. Travelers like it. It has a great reputation and it’s very close to Manhattan.”

As perceptions about Queens and the Bronx have shifted, their room rates have climbed. In Queens, the ADR rose by 5.1 percent to $157.59 and in the Bronx it went up 4.7 percent to $157.19, STR data covering the first 11 months of the year indicate. The borough’s hotel count increased from 113 last November to 122 today, supply increased 7 percent and occupancy crept up 1.3 percent to 85.5 percent. Hotel room supply in the Bronx jumped 9.2 percent, the number of hotels increased from 22 to 24 today and occupancy ticked up .3 percent to 72.6 percent. (In Staten Island, where the number of hotels remained the same at nine and supply and demand remained flat, the ADR dropped .5 percent to $126.67.)

If the number of rooms sold in Manhattan has increased 3.7 percent for the first 11 months of 2017 from the same period last year and the number of hotels rose from 416 last November to 428 today, why isn’t pricing following suit?

“That’s the billion-dollar question,” Freitag said.

He offered five potential reasons, but noted, “The truth is somewhere in the middle”: 1) With so much supply coming online (up 2.7 percent from 2016 at the same point), hoteliers don’t feel comfortable being aggressive in their pricing, 2) the ADR is already high, and the average guest doesn’t want to pay beyond that, 3) new entrants aren’t pricing as strong because they want to achieve occupancy, in turn dragging down the overall market prices, 4) more limited-service hotels are being built, which brings down the price point, and 5) hoteliers focus on hitting 95 percent occupancy, which allows them to get reimbursed by the brand at the ADR rather than a low fixed rate when guests pay for rooms with loyalty points.

As in Manhattan, citywide occupancy has risen this year, but pricing hasn’t follow suit. Through November, New York City hotels saw an 86.5 percent occupancy rate, up 1.1 percent from the same period last year, according to STR figures. ADR was $251, down 1.4 percent year-over-year. And the number of rooms under construction in New York City dipped by 2,000 rooms to 12,000 less than last year at the same time, but that is not anything to be worried about, Freitag said.

The Big Apple’s pipeline is “the highest of any market in the U.S,” he said. “The number we tracked a year ago was a high-water mark for rooms under construction in any market that we track since 1990.”


Source: commercial

Los Angeles and Orange County Among Top Markets for Office Market Growth

Los Angeles and Orange County were among the top three markets to get a boost in office market growth from the rise of the high-tech sector, according to CBRE’s annual Tech-30 report.

The report, which measures the tech industry’s impact on office rent in the 30 leading tech markets in the U.S. and Canada, found that Los Angeles County saw jobs in high-tech software/service sectors rise 20 percent during 2015-2016, nearly a three-fold increase from the prior two-year period’s 6.7 percent. Consequently, average office asking rents in Los Angeles climbed 11 percent to $37.08 per square foot annual from the second quarter of 2015 as compared to the same period in 2017. In the area’s top tech submarket in Santa Monica, average rents reached $71.28 during the period.

The rise in high-tech jobs and subsequent need for office space, has led companies either priced or locked out of high-demand areas on the Westside or near major entertainment studios, to the submarket of Downtown Los Angeles according to CBRE’s Senior Vice President John Zanetos. Vacancy rates in Downtown Los Angeles were 17 percent, for instance, compared to around 7 percent in Santa Monica, according to CBRE research.

“The space and the entertainment industries are merging in a very big way. That will continue to drive more of the big brand name technology companies into LA because of the need to be in the content creation and delivery business. I see this growing,” Zanetos told Commercial Observer.

He anticipates that lesser-known areas like Boyle Heights and Frog Town will be the next to benefit from the tech boom.

“You have these pockets of early 1900s industrial buildings that don’t really have an industrial use that can be converted in the same way that the Arts District was in Downtown LA and Culver City was,” he says. “They are close to public transit and the city of LA is going to be dumping a lot of money into those areas because of the LA River development plan and Sixth Street Viaduct redevelopment plan so they’re going to have a lot of benefit from public investment as well as having really cool buildings that can be converted into office space.”

Meanwhile, the OC led the country for rising office rents over the past two years.

Average office asking rents in Orange County climbed 23.3 percent to $33 per square foot annual from the second quarter of 2015 to the same period in 2017. The area’s top tech submarket — South Orange County — saw average rents reach $34.20 during the most recent period. Tech employment in Orange County increased 40.7 percent during 2005 and 2016, making it the top-growing industry in Orange County with approximately 300,000 sq. ft. of active requirements.

According to Allison Kelly, first vice president for CBRE, who has worked in the OC market for more than 13 years, office rents are primed for continued growth. For new to market properties, she expects the asking rents to increase to nearly $4 per square foot or $48 per square foot annual.

The drivers aside from lower rents than in high-demand markets in Los Angeles, she says, are the ability for companies to buy land and create buildings to suit them, proximity to mass transit and thousands of units of new housing being developed in the area, including residential units at the former El Toro Marine Corps base by FivePoint.

She also said the area attracts an educated, tech-savvy work force drawn to the region for lifestyle reasons.

“When people thought of tech companies, they were thinking of Mark Zuckerberg, bright kids in their early 20s in these startup companies with VC money, “said Kelly. “That might be a portion, but a lot of other people work in tech too, people in their 30s and 40s that have children, want to buy a home, are looking for that holistic quality of life and that is something that you can find in OC, where there are enough technology companies here, enough great talent for them to locate here, and a lot of options if you are an employee.”


Source: commercial

Los Angeles Is Tops for Foreign Investors in Industrial Real Estate

When it comes to foreign investment in industrial real estate, Los Angeles leads the nation, according to the latest research released last week by CBRE. In fact, the Greater Los Angeles area has attracted the most foreign capital—$1.4 billion in sales of buildings and properties — in the high-growth industrial sector since 2010. Other markets that saw significant foreign investment during this period include San Francisco/Oakland ($476 million), Seattle (with $449 million) and Phoenix (with $508 million). Each of these markets has benefitted from strong demographics and well-established logistics hubs, according to the CBRE findings.

Furthermore, the sector is taking an ever-larger piece of the foreign investment pie, driven in large part by the rise of e-commerce and the subsequent need for distribution and warehouse facilities to support it.

“Historically, the foreign investors had much more interest in hotels and hospitality and high-rise office buildings and more trophy assets,” CBRE’s Barbara Emmons-Perrier, a broker specializing in industrial, office and land sales, told Commercial Observer. “And in the last year or two years that’s shifted to logistics because of the rise of e-commerce. We were not a favored product class for a lot of this foreign investment until recently.”

Gateway locations to major metropolitan markets in the United States, like Los Angeles, (home to two of the nation’s biggest ports—Los Angeles and nearby Long Beach respectively)­ as well as its proximity to Asia-Pacific are particularly appealing. (Foreign investors have acquired nearly $61 billion in U.S. industrial real estate since 2010, 48 percent of which has come from Asia-Pacific-based investors—largely from Singapore and China, according to CBRE.)

“Foreign investors are very attracted to core gateway markets which would be obviously Los Angeles and New York,” Emmons-Perrier said. “They want something with a recognizable name. They’re not doing much in Ohio or Minneapolis or Iowa. They want all the top markets. There are tremendous amounts of those developments and opportunities in Southern California. From Asia, it’s an easy direct flight into [Los Angeles International Airport]. It’s the ports and a lot of good fundamental historical data that point to why it’s happening here.”


Source: commercial

Manhattan Office Leasing Activity Held Strong in Q3: CBRE

The Manhattan office leasing market continues to show signs of strength via positive net absorption figures and double-digit percent increases over last year, according to CBRE’s latest Manhattan office market report released today.

Total leasing activity of 7.4 million square feet in the third quarter outperformed the five-year quarterly average by 12 percent, and took total Manhattan office leasing activity for the first nine months of 2017 to 21.1 million square feet—a 24 percent increase, year-to-date, on 2016.

But perhaps the strongest indicator of the market’s strength so far this year was the 1.45 million square feet of positive net absorption registered last quarter. The Midtown market, in particular, posted more than 1 million square feet of positive absorption for the first time since the second quarter of 2015.

At a media briefing discussing the figures, Nicole LaRusso, CBRE’s director of research and analytics for the tri-state region, cited strong employment growth figures in New York City that she said “has really been fueling a lot of this [leasing] activity” in the Manhattan office market.

LaRusso was joined by CBRE Vice Chair Paul Amrich and Executive Vice President Neil King at the briefing, held at Rockpoint Group and Highgate Holdings’ office development at 412 West 15th Street in the Meatpacking District.

The property, which is still under construction as workers continue to build out the interiors, served as an ideal setting for a discussion on the state of the Meatpacking District and Hudson Square office market. According to the brokers, the area has changed “drastically” as larger, more mature companies view it as an increasingly viable office destination.

King said that the West Side neighborhood’s culinary and cultural amenities are among the reasons “why people want to be here”—citing Shake Shack’s recent 27,000-square-foot deal for its new headquarters and flagship restaurant at 225 Varick Street in Hudson Square, as well as institutions like the Whitney Museum of American Art, which moved to the Meatpacking District in 2015.

Amrich noted that more than ever, companies are using their real estate as a tool to recruit new, young talent—a trend that has extended from tech, media and creative firms into the realm of financial services and insurance companies. He cited insurer Argo Group, which inked a 48,000-square-foot lease at Rockpoint and Highgate’s Meatpacking project earlier this year, as well as Aetna’s recent agreement for 150,000 square feet at nearby 61 Ninth Avenue, developed by Vornado Realty Trust.

As far as Manhattan leasing activity on a submarket-by-submarket basis, CBRE said the Midtown market saw 4.84 million square feet of leasing activity in the third quarter, which constituted a 19 percent increase on the five-year average. Asking rents in Midtown stood at $80.54 per square foot, flat from the previous quarter but down 1 percent from the same period last year.

Midtown South registered 1.14 million square feet of activity—down 8.8 percent below the five-year average for the supply-constrained market and fueled mostly by small deals below 25,000 square feet, which constituted 59 percent of all transactions in the submarket last quarter. Midtown South asking rents of $71.90 per square foot—which LaRusso noted have run up dramatically over the past decade from their range in the low $40s per square foot in 2009—are flat from the previous quarter but up 4 percent year-over-year.

In the Downtown market, 1.43 million square feet of leasing activity in the third quarter was 9 percent over the five-year average, with government tenants—such as the city agencies that have flocked to the Verizon Building at 375 Pearl Street—accounting for 30 percent of all activity in the quarter. The submarket continues to see tenant migration trends work in its favor, with 1.5 million square feet of space in the year-to-date period comprising tenants who have moved Downtown from elsewhere in the city. Downtown asking rents were up 1 percent from the previous quarter, to $61.95 per square foot.


Source: commercial

Downtown Office Asking Rents Reach All-Time High: CBRE


Source: commercial

Retail Rents Drop Nearly 30 Percent Since 2014 Peak: Report

A struggling retail market means tenants are going to rent space this year for nearly a third less than they did during the retail peak in 2014, according to a new report from CBRE.

Average asking rents have dipped 2.7 percent across Manhattan retail corridors year-over-year. But the brokerage predicts that net effective rents—which factor in free months of rent and tenant improvements—will be substantially lower. Retail rents hit record highs in 2014, and today’s tenants will be able to sign leases at net effective rents that are 20 to 30 percent less than they did three years ago, CBRE’s report indicates.

Landlords would rather negotiate concessions (which decrease net effective rents) than lower asking rents in large part because they finance their buildings on the condition that they’ll secure certain rents.

“Investors have expectations of returns, so they need to keep rents at a certain level so they match the pro-forma,” CBRE researcher Nicole LaRusso, who authored the report, told Commercial Observer. “And then they negotiate all these concessions on the side. So asking rent might not be down, but net effective rents are.”

Cap rates for Manhattan retail properties have also shrunk to between 3 and 4 percent. The trend reflects a seller’s market where properties trade for steadily increasing prices, even as rents take a dive, LaRusso explained. It highlights the disconnect between Manhattan retail rents, which soared 90 percent between 2010 and 2014, and the borough’s retail sales, which grew 32 percent over the same period.

“In order to catch up to what landlords are looking to find in terms of rent, we need to see a little more growth in retail sales,” she added.

While average asking rents have dropped nearly everywhere in Manhattan since 2014, a handful of corridors have seen major dips. Rents along Broadway in Soho have slid 22 percent, and landlords on 34th Street in Herald Square are commanding 33 percent lower rents. Other hard-hit strips include Madison Avenue between East 57th and East 72nd Streets (21 percent decrease) and Broadway between West 72nd and West 86th Streets on the Upper West Side (25 percent decrease).

And the highest price corridors have seen some of the most precipitous rent decreases, because both luxury brand sales and tourism have declined over the past year, LaRusso said.

The brokerage blames declining rents on the growth of e-commerce, the overexpansion of national chains and the slow death of department stores.

“It’s one thing to open up a store on Third Avenue [or] on Columbus Avenue, [but] it’s a very different thing to open up a store on Fifth Avenue or Prince Street that could be a $5 [million] or $8 [million] or $10 million rent for a year,” said Cushman & Wakefield’s Alan Schmerzler. “For that rent, I could open several stores in malls around the country. Until rents come down to the point where I can defend that decision.”


Source: commercial