Administrative procedures structure how public agencies make decisions by controlling who participates, what information is considered, and how alternatives are evaluated. These procedures assume that the agency performing the work is the organization the procedure was designed to constrain. This study examines what happens when that assumption no longer holds. Using network analysis of inter-organizational correspondence and 43 expert interviews from the NEPA process, the study finds that consultants occupy the same structural position as public managers in coordination while remaining absent from the formal approval record. Procedural compliance and substantive agency engagement, once co-located, have separated. The procedural apparatus continues to function. It cannot detect the separation because compliant records look identical regardless of who produced the substantive work. Monitoring mechanisms depend on signals that something has gone wrong, and because the procedural apparatus produces none, the entire political controls framework ceases to function. The finding identifies a scope condition on a foundational assumption of democratic administration: that procedural compliance indicates political responsiveness. The constraining force of administrative procedures depends not on whether the procedure is followed but on the inter-organizational structure through which it is carried out, a condition that consultant-extended government has altered without changing the procedures themselves. 

A foundational assumption in public procurement and innovation policy is that competition drives value creation. This study tests that assumption in the context of complex infrastructure procurement, where alternative delivery methods give firms latitude to propose design solutions. Using fuzzy-set qualitative comparative analysis on 77 bids across 25 design-build projects and 40 expert interviews, this study finds that competition is neither a necessary nor sufficient condition for entrepreneurial behavior. Engineering complexity, best-value selection, and project size are the conditions that matter. The innovations that emerge are project-specific recombinations of existing techniques within regulatory constraints or bricolage that creates real value at the project level but whose situated nature limits what either party accumulates over time. For complex products procured under regulatory constraints, the mechanism that induces innovation is not what the literature assumes. 

Two articles are in preparation from this essay: one on the institutional conditions under which public procurement elicits entrepreneurial behavior, and one on the form innovation takes when it emerges under regulatory constraints. 

Theories of regulatory compliance explain variation through firm characteristics or enforcement style, holding the structural relationship between regulator and regulated constant. This study shows that the contract form itself determines what kind of regulatory relationship exists between the parties. Under alternative delivery, design is intentionally incomplete at environmental clearance, making reevaluation a structural feature of the delivery method and separating the party that made the environmental commitments from the party that controls the design process. Using a comparative case study of three projects under design-build, design-build-finance, and design-build-finance-operate-maintain, drawing from 25 elite interviews and over 6,700 pages of project documents, this study finds that the three contract forms produce qualitatively different regulatory relationships, not a simple gradient from more to less compliance. 

Two articles are in preparation from this essay: one on how contract form structures the regulatory relationship between parties, and one arguing that alternative delivery constitutes an unrecognized bottom-up streamlining process with implications for the program theory of environmental review.