For a lot of planners, the idea of an "infill exemption" to the California Environmental Quality Act has been a kind of holy grail over the past few years. CEQA is a fact of life in California and unlikely to go away. But having to run though the entire CEQA process for a project a quarter-acre infill site – just as you might for a project on 5,000 acres of raw land – has been more than a little frustrating for developers and planners alike. Sure, an infill project has an impact. But if getting environmental clearance is a hassle, then what's the point?

The past few years have been great for not building things. The Great Recession has particularly devastated developers building on the urban fringe, who found themselves saddled with entitlements for homes that no one would ever buy. 

But for a distinct group of non-developers, the so-called Great Recession has been great for business.