Some land-use and construction projects are large enough that their impacts extend well beyond the zoning tools municipalities typically rely on to govern them. Their physical and socioeconomic impacts can ripple across the entire city.
Major infrastructure projects — including large-scale data centers — can disproportionately affect electrical capacity, water resources, housing demand, municipal finances, the availability and affordability of essential services, and the overall resident quality-of-life experience.
When economic opportunity, infrastructure demands, environmental considerations, and community impacts converge, the challenge facing city leaders becomes far more complex than with typical zoning decisions.
In a previous article, “Data Center Governance: What We’re Learning,” I examined several of these converging pressures currently facing San Angelo, including housing constraints, infrastructure demands, community opposition concerned with transparency in decision making, and other potential impacts typical of large-scale developments, not just data centers.
So, how can municipalities responsibly evaluate projects whose impacts touch nearly every part of civic life — without either appearing to block opportunity or sacrifice quality of life?
The Zoning Governance Scale Issue: A Helpful Metaphor
Most zoning decisions rely on municipal process routine and a familiar zoning toolkit.
A restaurant, warehouse, or housing subdivision is proposed. Planning staff review the application, the Planning & Development Commission recommends a classification, and City Council applies one of the classification tools already available in the zoning code. For most development decisions, that toolkit works well. But occasionally a project arrives that is far larger than the tools we’re designed to handle.
Imagine opening a homeowner’s toolbox expecting a routine repair — and discovering the job actually requires a full contract construction yard: engineering plans, heavy equipment, materials, and specialized management expertise, as well as continuing project oversight afterward.
Hyperscale infrastructure projects, like data centers, present this problem for municipal governments. When projects reach a scale where their impacts ripple across an entire city, its resources, and its infrastructure, the question is no longer simply what zoning category applies. The challenge becomes whether a municipality’s governance tools operate at the same scale as the project being proposed.
Mastering the Dilemma
One possible approach is to adopt a structured civic governance model designed specifically for high-impact infrastructure decisions — one robust enough to address today’s challenges and durable enough to guide future ones.
I referred earlier to that model as CIVIG — Critical Infrastructure Verification & Impact Governance.
CIVIG – Upscaling Process to Govern High-Impact Projects
To be clear before proceeding, CIVIG does not attempt to decide whether a project should be approved.
Instead, it establishes a sturdy, transparent framework for how such decisions should be evaluated.
Purpose: Governance Goals
The CIVIG model begins with a simple premise: Governance scale must match project scale.
To achieve that, CIVIG is designed around several core goals.
1. Ensure that infrastructure and resource realities are evaluated early
Major projects can affect electrical capacity, water supply, housing markets, transportation systems, and emergency services.
CIVIG ensures these realities are examined before political approvals occur.
2. Establish a clear factual record
Complex projects often generate technical reports, modeling data, and engineering studies.
CIVIG organizes these materials into a transparent evidentiary record so that decision-makers and the public are evaluating the same information.
3. Strengthen transparency and public confidence
Public trust grows when residents can see how major infrastructure decisions are evaluated and when questions can be raised before final decisions are made.
4. Provide clarity and predictability for responsible developers
When expectations are clearly defined, applicants understand what information must be provided and what standards will guide the review process.
5. Support balanced integration among growth, infrastructure, resources, and quality of life
Cities regularly face difficult trade-offs among economic opportunity, infrastructure capacity, available resources, and the everyday quality-of-life experience of residents.
CIVIG helps ensure that these factors are evaluated together — before long-term commitments are made.
Process: Structuring Evaluation, Decision, and Execution
CIVIG translates these goals into a practical decision framework. Rather than allowing technical questions, political deliberation, and public concerns to collide in a single hearing, CIVIG organizes evaluation into a structured sequence, allowing each step to unfold in a logical civic sequence.
First, the technical realities are established.
Infrastructure capacity, resource demands, and potential community impacts are evaluated through required technical studies, supported by appropriate professional analysis and documentation.
Second, the public record is developed.
Residents, staff, and elected officials have access to the same information and are given adequate opportunity to question assumptions, identify gaps in analysis, make improvement recommendations, and affect outcomes.
Finally, elected officials deliberate and decide.
With the factual record established and key impacts understood, the Municipal Council can then exercise its policy judgment regarding whether and how a project should proceed.
In conclusion, the CIVIG structured approach—built for large-scale projects—helps communities evaluate major infrastructure decisions with clarity, transparency, and long-term perspective, then render sound judgment balancing growth with long-term community well-being.
Read the proposals and draft ordinance here:
