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Trump sues Palm Beach County for $100 million

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Donald Trump reportedly filed a lawsuit for $100 million against Palm Beach County alleging that the county’s airport is intentionally directing planes over his club at Mar-a-Lago.

The lawsuit is claiming that the county’s airport directors have pressured the Federal Aviation Administration to have air traffic controllers “deliberately and maliciously” direct almost all flights due east, including Trump’s plane, to fly directly over Mar-a-Lago.

Mar-a-Lago, which is only 10 minutes away from Trump International Golf Club West Palm Beach, was built in 1927 and is listed as a National Historic Landmark. Trump purchased the property in 1985 and reopened 10 years later after extensive renovations. Vibrations from the constant air traffic are supposedly causing irreparable damage the building’s antique tiles, roofing and foundation.

Trump may actually have a valid case for Private Nuisance, a tort claim in civil court. Under common law, a nuisance is an interference with a person’s use and enjoyment of his/her land. To win a private nuisance claim, Trump will have to show that the Palm Beach County either intentionally, negligently, or recklessly interfered with his enjoyment of the land or that Palm Beach County continued to send planes over the property after learning of the actual harm or substantial risk of future harm to the buildings structure.

This may actually be possible since this is the third time Trump sued the county for airplane noise. Trump first filed suit in 1995 which resulted in the county agreeing to lease Trump the land that was turned into Trump International Golf Club. He also sued in 2010 against the county alleging vibration damage to Mar-a-Lago which was later dismissed. These prior legal actions may be enough to show that Palm Beach County was aware of the potential damage air traffic may cause to Mar-a-Lago.

If a court does determine that Palm Beach County directed more planes over Mar-a-Lago with knowledge of the potential damage it may cause, Trump will then have to show that damage to Mar-a-Lago is substantial enough that it would offend an ordinary member of the community with normal sensitivity and temperament. It’s not a hard sell to say that an ordinary person would be offended by the continued damage to their antique building that is now used as an expensive private club.

Assuming that the court does find that the damage to Mar-a-Lago is substantial, it will then look to the reasonableness of the county’s conduct and balance the gravity of the harm to the usefulness of the conduct. This will be the stage in the case, assuming it goes to trial, where Trump will spare no expense bringing in air traffic control experts to show that the Palm Beach County Airport’s tactics are outside the standard practice by positioning all flights to fly directly over the piece of land where Mar-a-Lago sits.

There is still a good chance that this case may not go to trial; Palm Beach County Attorney’s have yet to be served with the complaint.  If it does get all the way to a jury, don’t be surprised to see Trump win.

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Evan is an attorney licensed to practice law in Michigan. He's also a dedicated golfer with an obsession for the latest golf equipment, and frequently gets caught in public examining his swing in any reflective surface.

26 Comments

26 Comments

  1. Mark

    Jan 17, 2015 at 8:48 am

    Is Donald Trump the most obnoxious and arrogant man in history?

  2. leftright

    Jan 14, 2015 at 10:36 pm

    I hope he wins because Palm Beach Country is a bastion of progressive elitist wealth, old money and blue haired arrogance. I didn’t leave anything there and hopefully they will drown in their wealth.

  3. EdJ

    Jan 14, 2015 at 6:58 pm

    Big Question….Have traffic patterns recently changed? If so why?

  4. gm

    Jan 14, 2015 at 4:54 pm

    he’s a smart guy…he should have thought this out before he bought the course. he now has to deal with the consequences. Its no different then people who complain about golf balls flying into their homes when they live on golf courses. Hey stupid ! you bought the house near landing zones for golf balls…its your problem, not the golfer.
    But this is typical Trump. Loves to here his own B.S. out of his mouth. And has anything that Trump has bought sucked ? NEVER, right !! Its amazing how whatever he touches is golden ! blowhard

    • marcel

      Jan 14, 2015 at 8:05 pm

      ahh i like your logic – so golfer is not responsible for shooting a ball at the house. its the house at fault. whats your handicap?

      • gm

        Jan 15, 2015 at 9:14 am

        maybe my last reply was too harsh for you Marcel…… so just in case the admin doesnt like my rhetoric, i will try again.
        Why you feel handicap has anything to do with anything, im amazed but you think it matters…its 2.1
        NOW to reiterate,
        How do you explain McIlroy’s pull hook into the house at the masters a few years back. Are you saying you have never missed a fairway ??? if you truly read my post, but you probably didnt based on your response, people who buy homes on golf courses (or buy courses next to airports, in trumps case) should have to suffer the consequences…I.E. airport noise…. golf balls hitting houses…… now do you get it ???????

    • ken

      Jan 22, 2015 at 9:11 pm

      That’s the question. Did KLNA change its departure pattern so that the predominant departure path is over the Trump property.
      One must remember. Palm Beach is loaded with old money limousine liberals…..
      Donald Trump is a hard working successful conservative.
      Do the math

  5. Primo

    Jan 14, 2015 at 10:49 am

    Trump is a bully, plain and simple. He’s leveraging for something he wants. The lawsuit is silly and wastes taxpayer dollars. But, Trump cares and is aware of only Trump at all costs. I guess he missed the Business Ethics course @ Wharton…

    • leftright

      Jan 14, 2015 at 10:33 pm

      He didn’t go to Wharton, perhaps that is why he is worth billions instead of running some fly by night.

      • JT

        Jul 5, 2015 at 1:54 pm

        He did go to The Wharton School at Pennsylvania.

  6. Jim

    Jan 14, 2015 at 9:27 am

    Seeing as how Mar-a-Lago was built in 1927, I think it was there LONG before the international airport was built.

  7. Steve

    Jan 13, 2015 at 3:03 pm

    trump is just pissed he is losing money at that course. I live in Palm beach and know caddies for his course and there is no work there, course is dead. As much as he will tell you his golf business is doing great. He said the same with his casino business.

  8. Double Mocha Man

    Jan 13, 2015 at 10:04 am

    Not a word in the article about the prevailing winds. Generally, for safety reasons, planes take off and land into the wind.

    • Nice

      Jan 13, 2015 at 10:19 am

      I think Trump can afford a lawyer that would have considered that defense.

      • ca1879

        Jan 13, 2015 at 12:04 pm

        Which has nothing to do with filing a suit. It’s all about applying pressure to gain advantage in the eventual resolution. They’ll say weather, Trump will say malice, untrained judge will rely on expert testimony which will conflict. The decision will come down to who tells the best tale. It’s unlikely to see a final decision unless one side or the other appears to have a slam dunk.

  9. Swang'nThemClubs

    Jan 13, 2015 at 2:24 am

    Buy property near an airport and then complain about the noise that comes along with having property near an airport…

    • other paul

      Jan 14, 2015 at 2:27 pm

      I lived close to an airport for a years, and a police friend of mine said that there is a lady who calls in and complains about noise 2 times per day. Every day.

  10. That guy

    Jan 12, 2015 at 11:47 pm

    it is possible to land and take off on a runway facing a different directions. Taxiing. Circling.

    • BAF

      Jan 13, 2015 at 9:16 pm

      Airplanes take off and land into the wind. That’s how airplanes work. When there’s no wind, there’s a preferred runway, which is the only thing that is up for debate. I’ve flown into and out of PBI in both directions, but that close to the water there is rarely a calm day.

  11. BAF

    Jan 12, 2015 at 10:59 pm

    Pull up Palm Beach Intl and Mar-a-Lago on Google maps. His club is due east of the east-bound runway. Having taken off from this airport many, many times, pilots aren’t even connecting to departure by the time their aircraft is over his club. What does he want them to do? He bought the airport knowing full well it was VERY close to a mid-sized airport which handles jet aircraft, one of which is his very own 727. The only self-serving egotistical person here is the Donald.

    • BAF

      Jan 12, 2015 at 11:00 pm

      Oooops…I meant bought the club knowing full well….

      • Double Mocha Man

        Jan 13, 2015 at 10:02 am

        There’s the solution! Trump should just buy the airport!

    • ken

      Jan 22, 2015 at 9:14 pm

      Yeah…That’s nice…The problem in your statement is that the airport in question is Palm Beach County Airpark ( KLNA) ….NOT Palm Beach Int’l (KPBI)

  12. Bob Smoth

    Jan 12, 2015 at 10:15 pm

    I hope Trump does win. Sometimes the people that sit on these city councils that implement and make decisions have their own prejudices towards people, Unfortuately most people don’t pay enough attention to these things. I’m glad Trump is standing up to these self serving egotistical people.

    • RG

      Jan 13, 2015 at 3:38 pm

      “I’m glad Trump is standing up to these self serving egotistical people.” Yes Donald Trump “Champion of The Little Guy.” I’m feeling pukey…

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Instruction

The Wedge Guy: The easiest-to-learn golf basic

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My golf learning began with this simple fact – if you don’t have a fundamentally sound hold on the golf club, it is practically impossible for your body to execute a fundamentally sound golf swing. I’m still a big believer that the golf swing is much easier to execute if you begin with the proper hold on the club.

As you might imagine, I come into contact with hundreds of golfers of all skill levels. And it is very rare to see a good player with a bad hold on the golf club. There are some exceptions, for sure, but they are very few and very far between, and they typically have beat so many balls with their poor grip that they’ve found a way to work around it.

The reality of biophysics is that the body moves only in certain ways – and the particulars of the way you hold the golf club can totally prevent a sound swing motion that allows the club to release properly through the impact zone. The wonderful thing is that anyone can learn how to put a fundamentally sound hold on the golf club, and you can practice it anywhere your hands are not otherwise engaged, like watching TV or just sitting and relaxing.

Whether you prefer an overlap, interlock or full-finger (not baseball!) grip on the club, the same fundamentals apply.  Here are the major grip faults I see most often, in the order of the frequency:

Mis-aligned hands

By this I mean that the palms of the two hands are not parallel to each other. Too many golfers have a weak left hand and strong right, or vice versa. The easiest way to learn how to hold the club with your palms aligned properly is to grip a plain wooden ruler or yardstick. It forces the hands to align properly and shows you how that feels. If you grip and re-grip a yardstick several times, then grip a club, you’ll see that the learning curve is almost immediate.

The position of the grip in the upper/left hand

I also observe many golfers who have the butt of the grip too far into the heel pad of the upper hand (the left hand for right-handed players). It’s amazing how much easier it is to release the club through the ball if even 1/4-1/2″ of the butt is beyond the left heel pad. Try this yourself to see what I mean.  Swing the club freely with just your left hand and notice the difference in its release from when you hold it at the end of the grip, versus gripping down even a half inch.

To help you really understand how this works, go to the range and hit shots with your five-iron gripped down a full inch to make the club the same length as your seven-iron. You will probably see an amazing shot shape difference, and likely not see as much distance loss as you would expect.

Too much lower (right) hand on the club

It seems like almost all golfers of 8-10 handicap or higher have the club too far into the palm of the lower hand, because that feels “good” if you are trying to control the path of the clubhead to the ball. But the golf swing is not an effort to hit at the ball – it is a swing of the club. The proper hold on the club has the grip underneath the pad at the base of the fingers. This will likely feel “weak” to you — like you cannot control the club like that. EXACTLY. You should not be trying to control the club with your lower/master hand.

Gripping too tightly

Nearly all golfers hold the club too tightly, which tenses up the forearms and prevents a proper release of the club through impact. In order for the club to move back and through properly, you must feel that the club is controlled by the last three fingers of the upper hand, and the middle two fingers of the lower hand. If you engage your thumbs and forefingers in “holding” the club, the result will almost always be a grip that is too tight. Try this for yourself. Hold the club in your upper hand only, and squeeze firmly with just the last three fingers, with the forefinger and thumb off the club entirely. You have good control, but your forearms are not tense. Then begin to squeeze down with your thumb and forefinger and observe the tensing of the entire forearm. This is the way we are made, so the key to preventing tenseness in the arms is to hold the club very lightly with the “pinchers” — the thumbs and forefingers.

So, those are what I believe are the four fundamentals of a good grip. Anyone can learn them in their home or office very quickly. There is no easier way to improve your ball striking consistency and add distance than giving more attention to the way you hold the golf club.

More from the Wedge Guy

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19th Hole

Vincenzi’s 2024 Texas Children’s Houston Open betting preview

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As the Florida swing comes to an end, the PGA Tour makes its way to Houston to play the Texas Children’s Houston Open at Memorial Park Golf Course.

This will be the fourth year that Memorial Park Golf Course will serve as the tournament host. The event did not take place in 2023, but the course hosted the event in 2020, 2021 and 2022.

Memorial Park is a par-70 layout measuring 7,432 yards and features Bermudagrass greens. Historically, the main defense for the course has been thick rough along the fairways and tightly mown runoff areas around the greens. Memorial Park has a unique setup that features three Par 5’s and five Par 3’s.

The field will consist of 132 players, with the top 65 and ties making the cut. There are some big names making the trip to Houston, including Scottie Scheffler, Wyndham Clark, Tony Finau, Will Zalatoris and Sahith Theegala.

Past Winners at Memorial Park

  • 2022: Tony Finau (-16)
  • 2021: Jason Kokrak (-10)
  • 2020: Carlos Ortiz (-13)

In this article and going forward, I’ll be using the Rabbit Hole by Betsperts Golf data engine to develop my custom model. If you want to build your own model or check out all of the detailed stats, you can sign up using promo code: MATTVIN for 25% off any subscription package (yearly is best value). 

Key Stats For Memorial Park

Let’s take a look at several metrics for Memorial Park to determine which golfers boast top marks in each category over their last 24 rounds:

Strokes Gained: Approach

Memorial Park is a pretty tough golf course. Golfers are penalized for missing greens and face some difficult up and downs to save par. Approach will be key.

Total Strokes Gained: Approach per round in past 24 rounds:

  1. Tom Hoge (+1.30)
  2. Scottie Scheffler (+1.26)
  3. Keith Mitchell (+0.97) 
  4. Tony Finau (+0.92)
  5. Jake Knapp (+0.84)

Strokes Gained: Off the Tee

Memorial Park is a long golf course with rough that can be penal. Therefore, a combination of distance and accuracy is the best metric.

Total Strokes Gained: Off the Tee per round in past 24 rounds:

  1. Scottie Scheffler (+0.94)
  2. Kevin Dougherty (+0.93)
  3. Cameron Champ (+0.86)
  4. Rafael Campos (+0.84)
  5. Si Woo Kim (+0.70)

Strokes Gained Putting: Bermudagrass + Fast

The Bermudagrass greens played fairly fast the past few years in Houston. Jason Kokrak gained 8.7 strokes putting on his way to victory in 2021 and Tony Finau gained in 7.8 in 2022.

Total Strokes Gained Putting (Bermudagrass) per round past 24 rounds (min. 8 rounds):

  1. Adam Svensson (+1.27)
  2. Harry Hall (+1.01)
  3. Martin Trainer (+0.94)
  4. Taylor Montgomery (+0.88)
  5. S.H. Kim (+0.86)

Strokes Gained: Around the Green

With firm and undulating putting surfaces, holding the green on approach shots may prove to be a challenge. Memorial Park has many tightly mowed runoff areas, so golfers will have challenging up-and-down’s around the greens. Carlos Ortiz gained 5.7 strokes around the green on the way to victory in 2020.

Total Strokes Gained: Around the Green per round in past 24 rounds:

  1. Mackenzie Hughes (+0.76)
  2. S.H. Kim (+0.68)
  3. Scottie Scheffler (+0.64)
  4. Jorge Campillo (+0.62)
  5. Jason Day (+0.60)

Strokes Gained: Long and Difficult

Memorial Park is a long and difficult golf course. This statistic will incorporate players who’ve had success on these types of tracks in the past. 

Total Strokes Gained: Long and Difficult in past 24 rounds:

  1. Scottie Scheffler (+2.45)
  2. Ben Griffin (+1.75)
  3. Will Zalatoris (+1.73)
  4. Ben Taylor (+1.53)
  5. Tony Finau (+1.42)

Course History

Here are the players who have performed the most consistently at Memorial Park. 

Strokes Gained Total at Memorial Park past 12 rounds:

  1. Tyson Alexander (+3.65)
  2. Ben Taylor (+3.40)
  3. Tony Finau (+2.37)
  4. Joel Dahmen (+2.25)
  5. Patton Kizzire (+2.16)

Statistical Model

Below, I’ve reported overall model rankings using a combination of the five key statistical categories previously discussed.

These rankings are comprised of SG: App (24%) SG: OTT (24%); SG: Putting Bermudagrass/Fast (13%); SG: Long and Difficult (13%); SG: ARG (13%) and Course History (13%)

  1. Scottie Scheffler
  2. Wyndham Clark
  3. Tony Finau
  4. Joel Dahmen
  5. Stephan Jaeger 
  6. Aaron Rai
  7. Sahith Theegala
  8. Keith Mitchell 
  9. Jhonnatan Vegas
  10. Jason Day
  11. Kurt Kitayama
  12. Alex Noren
  13. Will Zalatoris
  14. Si Woo Kim
  15. Adam Long

2024 Texas Children’s Houston Open Picks

Will Zalatoris +2000 (Caesars)

Scottie Scheffler will undoubtedly be difficult to beat this week, so I’m starting my card with someone who I believe has the talent to beat him if he doesn’t have his best stuff.

Will Zalatoris missed the cut at the PLAYERS, but still managed to gain strokes on approach while doing so. In an unpredictable event with extreme variance, I don’t believe it would be wise to discount Zalatoris based on that performance. Prior to The PLAYERS, the 27-year-old finished T13, T2 and T4 in his previous three starts.

Zalatoris plays his best golf on long and difficult golf courses. In his past 24 rounds, he ranks 3rd in the category, but the eye test also tells a similar story. He’s contended at major championships and elevated events in the best of fields with tough scoring conditions.  The Texas resident should be a perfect fit at Memorial Park Golf Club.

Alex Noren +4500 (FanDuel)

Alex Noren has been quietly playing some of his best golf of the last half decade this season. The 41-year-old is coming off back-to-back top-20 finishes in Florida including a T9 at The PLAYERS in his most recent start.

In his past 24 rounds, Noren ranks 21st in the field in Strokes Gained: Off the Tee, 30th in Strokes Gained: Around the Green, 25th in Strokes Gained: Total on long and difficult courses and 21st in Strokes Gained: Putting on fast Bermudagrass greens.

In addition to his strong recent play, the Swede also has played well at Memorial Park. In 2022, Noren finished T4 at the event, gaining 2.2 strokes off the tee and 7.0 strokes on approach for the week. In his two starts at the course, he’s gained an average of .6 strokes per round on the field, indicating he is comfortable on these greens.

Noren has been due for a win for what feels like an eternity, but Memorial Park may be the course that suits him well enough for him to finally get his elusive first PGA Tour victory.

Mackenzie Hughes +8000 (FanDuel)

Mackenzie Hughes found himself deep into contention at last week’s Valspar Championship before faltering late and finishing in a tie for 3rd place. While he would have loved to win the event, it’s hard to see the performance as anything other than an overwhelming positive sign for the Canadian.

Hughes has played great golf at Memorial Park in the past. He finished T7 in 2020, T29 in 2021 and T16 in 2022. The course fit seems to be quite strong for Hughes. He’s added distance off the tee in the past year or and ranks 8th in the field for apex height, which will be a key factor when hitting into Memorial Park’s elevated greens with steep run-off areas.

In his past 24 rounds, Hughes is the best player in the field in Strokes Gained: Around the Greens. The ability to scramble at this course will be extremely important. I believe Hughes can build off of his strong finish last week and contend once again to cement himself as a President’s Cup consideration.

Akshay Bhatia +8000 (FanDuel)

Akshay Bhatia played well last week at the Valspar and seemed to be in total control of his golf ball. He finished in a tie for 17th and shot an impressive -3 on a difficult Sunday. After struggling Thursday, Akshay shot 68-70-68 in his next three rounds.

Thus far, Bhatia has played better at easier courses, but his success at Copperhead may be due to his game maturing. The 22-year-old has enormous potential and the raw talent to be one of the best players in the world when he figures it all out.

Bhatia is a high upside play with superstar qualities and may just take the leap forward to the next stage of his career in the coming months.

Cameron Champ +12000 (FanDuel)

Cameron Champ is a player I often target in the outright betting market due to his “boom-or-bust” nature. It’s hard to think of a player in recent history with three PGA Tour wins who’s been as inconsistent as Champ has over the course of his career.

Despite the erratic play, Cam Champ simply knows how to win. He’s won in 2018, 2019 and 2021, so I feel he’s due for a win at some point this season. The former Texas A&M product should be comfortable in Texas and last week he showed us that his game is in a pretty decent spot.

Over his past 24 rounds, Champ ranks 3rd in Strokes Gained: Off the Tee and 30th in Strokes Gained: Total on long and difficult courses. Given his ability to spike at any given time, Memorial Park is a good golf course to target Champ on at triple digit odds.

Robert MacIntyre +12000 (FanDuel)

The challenge this week is finding players who can possibly beat Scottie Scheffler while also not dumping an enormous amount of money into an event that has a player at the top that looks extremely dangerous. Enter McIntyre, who’s another boom-or-bust type player who has the ceiling to compete with anyone when his game is clicking on all cylinders.

In his past 24 rounds, MacIntyre ranks 16th in the field in Strokes Gained: Off the Tee, 17th in Strokes Gained: Around the Green and 10th in Strokes Gained: Total on long and difficult courses.

MacIntyre’s PGA Tour season has gotten off to a slow start, but he finished T6 in Mexico, which is a course where players will hit driver on the majority of their tee shots, which is what we will see at Memorial Park. Texas can also get quite windy, which should suit MacIntyre. Last July, the Scot went toe to toe with Rory McIlroy at the Scottish Open before a narrow defeat. It would take a similar heroic effort to compete with Scheffler this year in Houston.

Ryan Moore +15000 (FanDuel)

Ryan Moore’s iron play has been absolutely unconscious over his past few starts. At The PLAYERS Championship in a loaded field, he gained 6.1 strokes on approach and last week at Copperhead, he gained 9.0 strokes on approach.

It’s been a rough handful of years on Tour for the 41-year-old, but he is still a five-time winner on the PGA Tour who’s young enough for a career resurgence. Moore has chronic deterioration in a costovertebral joint that connects the rib to the spine, but has been getting more consistent of late, which is hopefully a sign that he is getting healthy.

Veterans have been contending in 2024 and I believe taking a flier on a proven Tour play who’s shown signs of life is a wise move at Memorial Park.

 

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Opinion & Analysis

Ryan: Why the race to get better at golf might be doing more harm than good

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B.F. Skinner was one of the most important psychologists of the 20th century, developing the foundation of the development of reinforcement, and in doing so, creating the concept of behaviorism. In simple terms, this means that we are conditioned by our habits. In practical terms, it explains the divide between the few and far between elite instructors and college coaches.

To understand the application, let’s quickly review one of B.F. Skinner’s most important experiments; superstitions in the formation of behavior by pigeons. In this experiment, food was dispensed to pigeons at random intervals. Soon, according to Skinner, the pigeons began to associate whatever action they were doing at the time of the food being dispensed. According to Skinner, this conditioned that response and soon, they simply haphazardly repeated the action, failing to distinguish between cause and correlation (and in the meantime, looking really funny!).

Now, this is simply the best way to describe the actions of most every women’s college golf coach and too many instructors in America. They see something work, get positive feedback and then become conditioned to give the feedback, more and more, regardless of if it works (this is also why tips from your buddies never work!).

Go to a college event, particularly a women’s one, and you will see coaches running all over the place. Like the pigeons in the experiment, they have been conditioned into a codependent relationship with their players in which they believe their words and actions, can transform a round of golf. It is simply hilarious while being equally perturbing

In junior golf, it’s everywhere. Junior golf academies make a living selling parents that a hysterical coach and over-coaching are essential ingredients in your child’s success.

Let’s be clear, no one of any intellect has any real interest in golf — because it’s not that interesting. The people left, including most coaches and instructors, carve out a small fiefdom, usually on the corner of the range, where they use the illusion of competency to pray on people. In simple terms, they baffle people with the bullshit of pseudo-science that they can make you better, after just one more lesson.

The reality is that life is an impromptu game. The world of golf, business, and school have a message that the goal is being right. This, of course, is bad advice, being right in your own mind is easy, trying to push your ideas on others is hard. As a result, it is not surprising that the divorce rate among golf professionals and their instructors is 100 percent. The transfer rate among college players continues to soar, and too many courses have a guy peddling nefarious science to good people. In fact, we do at my course!

The question is, what impact does all this have on college-age and younger kids? At this point, we honestly don’t know. However, I am going to go out on a limb and say it isn’t good.

Soren Kierkegaard once quipped “I saw it for what it is, and I laughed.” The actions of most coaches and instructors in America are laughable. The problem is that I am not laughing because they are doing damage to kids, as well as driving good people away from this game.

The fact is that golfers don’t need more tips, secrets, or lessons. They need to be presented with a better understanding of the key elements of golf. With this understanding, they can then start to frame which information makes sense and what doesn’t. This will emancipate them and allow them to take charge of their own development.

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