Discernment beyond procedure.

Every project is decided long before it is approved. Its terms are fixed, its constraints accepted, its description written, its plan set, and each of those decisions is made by someone, whether or not anyone notices it being made. Most practitioners inherit those decisions and price the consequences. We make them, from the first question, while what is possible is still open, what is required is still testable, and how the project will be described is still ours to write. And we stay when the plan meets the world.

COMPASS

Planning is judgment applied to two questions: what should be built, and how it reaches the ground. Four principles govern how we answer them, and they follow the life of a project: what is possible, what is required, who defines it, and what happens when it changes.

Feasibility is a design decision.

Feasibility governs more decisions than any other word in development, and nearly everyone treats it as something to be discovered. A site is feasible or it is not; a schedule can be met or it cannot; a measure is infeasible and so is set aside. Yet nothing is infeasible in itself, only against terms someone has already fixed: a budget, a delivery date, a design already drawn, objectives written to fit that design. Move the terms and the finding moves with them. And more becomes fixed the longer a project runs, so the finding depends less on the analysis than on when the question is asked. Asked after the design is set, feasibility is a formality with a foregone conclusion. Asked while the terms are still open, it is a design decision, and the proponent who makes it decides what the project can become.

A constraint is not real until it has been tested.

Every constraint presents itself with the same authority, whatever its origin. Some protect an interest enumerated by statute. Others are habits: studies and thresholds that accumulated around a protection and persist after the reason for them has gone, requested so often that the people requesting them can no longer say what they protect. On the page the two are indistinguishable. A constraint is real when its purpose can still be found. Testing one means tracing it back to that purpose and asking whether the purpose still holds. The test is the opposite of evasion. A constraint understood is a constraint met directly, and met directly it costs a fraction of what it costs when it is merely obeyed.

A project is reviewed as it is described.

Before any rule applies to a project, someone has to say what the project is, and that description decides which rules apply. It determines the lead agency, the level of review, whether an approval is discretionary or ministerial, what counts as the baseline, and which alternatives must be studied. Whoever supplies the description first supplies it for everyone: the agency writes its notice from it, the neighbors argue from it, the lender prices from it, and each later description is measured against the first. A proponent who leaves the definition to others spends the review contesting it. A proponent who defines the project completely, early, and truthfully spends the review confirming it. We write the first description, and we write it to hold.

The destination outlasts the plan.

The best-laid plans have a well-known fate, and no project, however carefully prepared, is built as it was first drawn. Agencies reorganize. Markets move. A study returns a finding no one expected, or a decision-maker leaves, or the law itself changes mid-review. The plan was always provisional. The destination was not. Holding to it means adjusting early and without drama, keeping the record intact through every revision, and staying with the project in every forum where its interests must be defended: before staff, before commissions, and if it comes to that, before a court. We have carried projects through all of them. That is where a practice is measured.

BEARINGS

The people who understand your project do the work on it, from the first question to the final approval. No file passes to an analyst who has never seen the site. We keep the firm small so that this remains true. Size buys capacity and sells it by the hour; a small practice sells judgment, and can decline the work it cannot think through. The constraint is chosen.

The work spans the life of a project:

  • Feasibility and critical-issues analysis

  • Land use and master planning

  • Environmental review under CEQA and NEPA

  • Permitting and licensing, local through federal

  • Due diligence and site assessment

  • Public finance and funding strategy

  • Development management

It has been done on energy, transportation, ports and terminals, water and wastewater, land development, institutional and public facilities, agriculture and resource lands, and industrial and process facilities. Two decades of it, much on large and contested projects, and much the kind that never appears in a brochure because it was slow and then, finally, successful.

TRACK RECORD

The range is the argument. Judgment tested in one kind of project stays narrow, however deep it runs. Tested across many, over two decades, through projects that were contested and litigated, it becomes something more useful: the capacity to read a situation no one has seen before, and to hold a project together when it turns difficult.

Energy

Feasibility · planning · environmental review · permitting and licensing · due diligence · development management

  • California Energy Commission applications for certification: Elk Hills (500 MW), Sutter, Pico, Roseville Energy Park, with expert testimony at evidentiary hearings

  • California–Oregon 500 kV transmission: corridor analysis across 1,200 miles of alternatives for a 340-mile line, joint EIR/EIS

  • PG&E electric transmission planning and permitting support contract; Kirkwood Meadows 115 kV; Tesla–Metcalf 500 kV tower siting

  • Wind: Shiloh, Klondike III, Big Horn, Hoffman Summit

  • Solar and storage: NVSolarWRX (450 MW, Washoe County, Nevada UEPA); Calneva and Stacy solar-plus-storage; Tierra Buena BESS

  • Pipeline and asset diligence: ExxonMobil Pipeline, Enbridge, Merit Energy, Copperwood

Transportation

Planning · environmental review · permitting · public finance

  • Kern and Butte County regional transportation plans and program EIRs

  • Highway 70/99 corridor study; Kern River Canyon alignment; SR-178 corridor

  • Lake Tahoe Boulevard lane reduction; Castroville rail-crossing pedestrian bridge

  • TxDOT statewide environmental on-call; FM 1925 and I-35 widening

  • Bakersfield intermodal center site location; regional airport system plan

Ports and terminals

Feasibility · environmental review · permitting and licensing · due diligence · development management

  • Targa Port of Stockton marine oil terminal, unit train, and tank farm: planning, CEQA certification, MOTEMS audit, permitting (verify: only MOT certified in California in roughly two decades)

  • NuStar Selby crude-by-rail expansion; Endicott biofuel production facility

  • Targa acquisitions: Tacoma, Baltimore, Perth Amboy, Channelview

  • Vopak North America: fifteen-port acquisition review

  • Port of Coos Bay North Spit terminal feasibility; Port St. Joe master plan; Kiewit Bay Bridge precast facility

Water and wastewater

Planning · environmental review · permitting · public finance

  • Little Butte Creek watershed protection ordinance, Butte County, defended to the California Supreme Court

  • Mammoth Lakes drainage master plan; Putah Creek urban runoff accord

  • Greenwood Reservoir water treatment plant, joint EIR/EA; Mather Field perchlorate cleanup

  • Chinook River estuary restoration; City of Benicia water and wastewater on-call

Land development

Feasibility · planning · environmental review · permitting · public finance

  • Winters and Arvin general plans and zoning codes; Butte County community plans

  • Harrison Ranch land-use alternatives, 1,100 acres, for the Shriners Hospitals

  • River View Employment Center EIR; Clearvista Ranch EIR; Riverdale North

  • Sutter Hill transit village plan and funding plan

Institutional and public facilities

Planning · environmental review · permitting

  • CSU Chico campus master plan program EIR, litigated by the City of Chico, upheld

  • Bakersfield College Northwest Center specific plan; Los Angeles Mission College master plan

  • CDCR secure reentry facilities: site selection and critical issues, thirty-two sites; RJ Donovan health-care facility CEQA review

  • Oakland Army Base and Sacramento Army Depot disposal and reuse EISs

  • Lincoln and Twelve Bridges school campuses; Butte County Fire Station 27

Agriculture and resource lands

Environmental review · permitting · planning

  • Madera dairies: four EIRs on 16,000 acres, 21,000-head herd; Red Top Jerseys; Gomes Dairy

  • Table Mountain gravel mine EIR and conditional use permit

  • Los Padres and Custer National Forest oil-and-gas leasing EISs; Alpine Satellite EIS, National Petroleum Reserve–Alaska

  • Bakersfield College farmland conversion study; Sierra Pacific Industries watershed pollution-risk study

Industrial and process facilities

Feasibility · due diligence · permitting · environmental review

  • SiONEER glass recycling, Port of Stockton: independent engineer's report for CPCFA bonds, Phase I and II

  • Yellowstone Biomass (Ore-Ida), Ontario, Oregon: full permit set; Canby biomass feasibility and IS/MND

  • Tremont Group risk management plans; Wilbur-Ellis and Helena Chemical SPCC programs

  • Beacon Industries facility assessments, eight sites

What the range has taught us

The technical analysis is rarely the hard part. Coordination is: overlapping jurisdictions, agencies with crossing mandates, stakeholders who needed to be in the room before they were. We map that terrain before the site.

Trouble is predictable. Almost always it traces to one early decision, made on an assumption no one examined, that everything afterward was built upon. Knowing where to look is most of the value.

Starting a project and rescuing one are different skills. Across the documents we have carried through litigation, none has been found inadequate by a court. The work does not end when a project gets hard, and neither do we.

Contact

If your project is making you ask what is actually required, and what only appears to be, we should talk. The work is most useful early but a conversation is welcome at any stage.