Office of Counsel - Make the Call

 "John Minor Wisdom, Office of Counsel."

"Um."

So starts your discussion with Office of Counsel.  You are off to a good start.  Ultimately**, you are turned back to planning - this is a policy decision, rather than a legal one - on whether the program is eligible for a combination of old and new projects.  BUT!

But there is a concern from your OC teammate about considering railroad companies as public infrastructure.  They serve a critical function, transport commodities and the public, but are NOT considered public infrastructure, and are not subject to protection from the CAP 14 program.  It doesn't rule out the use of Section 14, but might make it harder to capture the benefits.

So you didn't get any closer for having requested the help.  But at least you know that you are not worrying about a failed project resulting from not having a solid authority nailed down.  

Remind me again - why is there a set of scales here?  

So you go to the Regional Planning Chief for additional help, who asks why you didn't read the guidance for CAP.

"Wait, what?"

You open up your dog-eared copy of EP1105-2-58, turning to the pertinent page on Section 14 studies.  And sure enough, 

Well, crap.

Not only do you not have an authority you can use, you also managed to look like an idiot in front of the planning chief. Not quite an RGE (Resume Generating Event), but it is not a good look.  

Note to self, you can never go wrong with consulting the guidance first.  

Welp, I guess it is back to the Authorities Page.  

**For the record, this advice does not come from OC - I am just providing narrative.  For real answers, please consult your district office of counsel.