A Guide to Quantifying CRE Entitlement Risk (introducing Entitlement Risk Reports)

An overview of how Epum quantifies entitlement risk for commercial real estate development projects across the US. All entitlement data is from the Epum platform which can be accessed at: https://www.epum.com/

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Leonardo Costa, Rath Sanguanthai & Royden Cooper
July 04, 2025

What is the Entitlement Process?

The entitlement process for commercial real estate development can be the defined as the process by which a developer secures municipal government and community approval to build a specific proposed development and then begin construction. The entitlement process typically costs $200-400k per project and takes 12-24 months, but it can cost millions and take many years if the project is truly transformational for a municipality.

What is Political Risk?

During the entitlement process, elected officials from the local Planning & Zoning Commission, Design Review Committee, or other relevant committees can derail your entitlement process. Understanding the voting histories and current election term for each relevant elected official can help you decrease political risk for your entitlement process.

What is Community Risk?

It is essential to understand the “development-friendliness” of local communities since community members may be able to appeal your planning application and delay or derail your overall entitlement process. NIMBYism (“Not In My Backyard”) is a rampant problem which contributes to the housing crisis in the United States. Avoiding “NIMBY communities” by analyzing the meeting minutes from past public hearings for other similar commercial real estate projects and conducting sentiment analysis on local news and social media outlets can allow a develop to avoid years of headache and lost entitlement costs.

Sample Entitlement Risk Report

Subject Municipality: Greensboro, North Carolina

Subject Entitlement Type: Rezoning

Subject Project in Planning: Industrial (a distribution center)

1. Project Approval Rate Analysis

Approval Rate Analysis for all Projects (last 5 years):

Approval Status

Count

% of Total

Approved

181

75%

Approved with Conditions

23

9%

In Public Hearing

20

8%

Rejected

14

6%

Deferred

4

2%

Subtotal:

242

100%

Approval Rate Analysis for Industrial Projects (last 5 years):

Approval Status

Count

% of Total

Approved

36

88%

Approved with Conditions

0

In Public Hearing

3

8%

Rejected

1

2%

Deferred

1

2%

Subtotal:

41

100%

2. Overview of the Rezoning Entitlement Process & Summary of Key Risk(s)

The Epum team spoke to Andrew Nelson from the Greensboro Planning & Zoning Commission ([email protected]). He was a great guy and incredibly helpful. The rezoning process in Greensboro seems to be efficient and the velocity of planning approvals over the last few years shows that Greensboro is a development-friendly municipality.

Overview of the Rezoning Application Process:

  • Rezoning applications must be filed no later than 45 days prior to the target zoning hearing date.

  • The application includes:

    • Application Information

    • Owner Info (if different)

    • Map

      • A boundary survey or map of the subject property

    • Legal Description

      • A legal description of the subject property (metes and bounds)

    • Zoning request and initial conditions if applicable

      • Zoning conditions are a tool available to the property owner in tailoring an original zoning request to fit the needs of their development and the environment of the surrounding community. Only the property owner may propose conditions, which are binding on the property. Valid zoning conditions must be legally enforceable, clearly written to be reviewable by the standards of the Land Development Ordinance (LDO), and more stringent than the baseline requirements imposed by the Ordinance.

  • Developers should reach out to Marjorie Manzanares from the Greensboro Department of Transportation (GDOT) to confirm the potential need for a Traffic Impact Study ([email protected]).

    • A 'Traffic Impact Study (TIS)’ is needed depending on the project’s use. The TIS draft is due 21 days prior to the application being filed.

  • Neighborhood outreach is a vital part of the zoning process. The City of Greensboro has a website with resources and information available to you in helping plan your community engagement:

    • https://www.greensboro-nc.gov/departments/planning/learn-more-about/zoning-rezoning/zoning-rezoning-outreach.

      • This page has information about options available to you for communicating about your request, but the specific measures you choose to take should be tailored to the surrounding community. You will notice the Summary of Neighborhood Communications form attached in the rezoning application (see below). This form is due back to the Planning Department the Thursday before your scheduled Planning and Zoning Commission meeting. Planning staff will provide you with a list of all property owners within the 750-foot required official notice distance of the subject property who will receive letters from the City after a rezoning application is submitted.

  • Each Planning & Zoning Commission includes a public hearing process where community members can file complaints.

    • Projects can go for inclusion on expedited agendas if there are no complaints. Approval in this case could take 60-90 days.

    • State law dictates that the public must be notified 10-25 days prior to the public hearing. Public notification must take the form of Posted Notices (at your project), newspaper ads (2 consecutive weeks with the first ad running more than 10 days prior to the hearing), and web notice through the Greensboro Zoning Commission web link.

  • The Staff Review Process includes:

    • (Recommended but not mandatory) Pre-application meeting to review zoning viability and zoning options

    • Sufficiency Review (includes Transportation and Long-Range Planning staff)

    • Site Visits

    • Preparation of Staff Report and Official Recommendation

Key Risk(s)

The key risk for the rezoning process in Greensboro, NC is during the public hearing stage. Out of a recent sample of 53 residential and industrial projects, 13 of them had public opposition and 2 of them were denied by the Planning & Zoning Commissioners in the end. Both of the denials were multi-family projects.

The Epum team summarized public concerns from past Planning & Zoning Commission meetings by analyzing the meeting minutes from the respective meetings, with the following feedback by product type:

  • Industrial

    • Community opposition focuses on concerns that the proposed industrial rezoning may violate zoning regulations and create public safety and environmental risks. Residents worry that local roads are too narrow to safely handle increased freight traffic, raising issues of congestion and pedestrian safety. There is also apprehension about negative impacts on neighborhood quality and property values, with calls to concentrate industrial development near major highways to better accommodate heavy traffic and protect residential areas.

  • Multi-family Housing

    • Community opposition to the proposed multifamily housing rezoning centers on concerns about excessive density, traffic congestion, pedestrian safety, and environmental constraints such as stormwater runoff into nearby streams. Residents expressed frustration with inadequate technical review, insufficient community engagement, and unclear site plans, fearing the project’s scale and design would disrupt neighborhood character and strain existing infrastructure. Additional worries include building height, proximity to incompatible uses, parking shortages, emergency access, and potential short-term rental impacts, with many calling for more thorough analysis and better transparency before land use decisions which permit more multi-family housing.

  • Single-family Housing

    • Community opposition highlights concerns about traffic impacts from limited access, potential effects on property values and safety, and inadequate community engagement. Residents emphasized incompatibility of single-family development with existing and planned heavy industrial uses, stressing the need to protect industrial lands and neighborhood character consistent with the GSO2040 Comprehensive Plan. Additional worries include narrow local roads, environmental impacts related to nearby ponds and wildlife, and proposed lot sizes and density that conflict with neighborhood preferences for larger lots and privacy.

3. Profiles of Relevant Elected Officials (Greensboro Planning & Zoning Commission)

Epum | CRE Entitlement Data & Urban Growth Analytics

Track, visualize, and analyze parcel-level entitlement data, including site plan approvals, rezonings, special exceptions, and more throughout the US.

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