permitting efficiency study

This report is intended for the internal use of the City of Santa Monica, and may not be provided to, used, or relied upon by any third parties.

FINAL REPORT

City of Santa Monica PERMITTING EFFICIENCY STUDY

May 11, 2021

Moss Adams LLP 999 Third Avenue, Suite 2800

Seattle, WA 98104 (206) 302-6500

Permitting Efficiency Study Report

FOR INTERNAL USE OF CITY OF SANTA MONICA ONLY

Table of Contents

Executive Summary 3

A. Background, Scope, and Methodology 3

B. Summary of Observations and Recommendations 3

Background, Scope, and Methodology 7

A. Background 7

B. Scope and Methodology 7

Commendations 9

Observations and Recommendations 10

A. Regulatory Environment 10

B. Processes and Systems 13

C. Customer Service 30

Appendix A: Employee Survey Results 35

Appendix B: Customer Survey Results 46

Permitting Efficiency Study Report | 3


EXECUTIVE SUMMARY

The newly formed Community Development Department (the Department) works with the community to enhance the character, safety, and neighborhoods within the City of Santa Monica (the City). One of the core functions of the Department includes leading the City’s building permitting services, including permit application intake and routing, building code plan check, planning plan check, and inspections. Depending on the type of permit, other divisions from across the City may also be involved in the permit process.

The City is experiencing unprecedented challenges, including a remote work environment and staffing cuts, due to the impacts of COVID-19. At the same time, the City’s local economy, including retailers, restaurants, and hospitality providers, has suffered as a result of shelter-in-place orders and occupancy restrictions, with an estimated 300 small businesses closing their doors. The City’s permitting process has long been a concern for the small business community, due to its complexity and length. The City has an opportunity to modify and streamline the permitting process to be more accessible to and efficient for small businesses, with the ultimate goal of supporting local economic recovery.

This study was designed to assess the economy, efficiency, and effectiveness of the City’s permitting process, led primarily by the Planning and Building and Safety divisions within the Community Development Department. Its goal is to enhance the ability to meet the needs of the community in a reduced resource environment.

Given the challenges currently facing the City, this study focused primarily on the permitting experience for property owners and small business customers. Analysis was informed by employee interviews, document review, an internal staff survey, an external customer survey, small business focus groups, and research into best practices for similar cities across the country. The study was conducted between December 2020 and May 2021.

The City’s permitting process has been developed piecemeal over the course of several decades to reflect shifting community values, and thus has become increasingly onerous for small businesses and residential property owners. Historically, business development has not been a top priority when considering community values; however, the pandemic has resulted in hardships for many small businesses in the community. In order to support local economic recovery and retain the City’s previous vibrant small business community, the permitting process should be redesigned, clarified, and automated to the extent possible. This work requires a cross-functional approach to assessing permit requirements, revising the municipal code as necessary, and collaborating closely to support an improved customer experience. Significant initiatives to complete this work include:

Conducting a comprehensive review of permitting requirements in the municipal code to streamline definitions, thresholds, and roles and responsibilities (Recommendation #1).

In alignment with the revised municipal code, streamlining plan check and inspection processes through implementation of a user-friendly system, guidance and checklists for employees



performing plan check, and prioritizing plan checks among other employee duties. (Recommendations #4, #5A, #5C, #6).

Improving the customer experience by designating a point-person for customer inquiries, adopting a service philosophy, redesigning the permitting website, and creating user-friendly permitting educational materials related to requirements and processes (Recommendations #3, #9, #10).

The recommendations included in this report represent a change in philosophy and will require additional resources in the form of external consultants and temporary staffing to complete, as noted in the implementation plan. Finally, to successfully create a streamlined, user-friendly permitting process, there must be alignment and buy-in among the community, City Council, and city employees.

Our complete set of observations and recommendations are presented below in three categories: Regulatory Environment, Processes and Systems, and Customer Service.

OBSERVATIONS AND RECOMMENDATIONS

Regulatory Environment

1.

Observation The City has established regulations in alignment with community values; however, these regulations create complexity in the process for both customers and City staff.

Recommendation Establish a cross-functional committee to conduct a comprehensive permitting requirements inventory and mapping, to identify opportunities to simplify and streamline the municipal code.

2.

Observation Due to physical space limitations on parcels, there are sometimes conflicts between existing City codes that require staff and customer involvement to resolve on a case-by-case basis.

Recommendation

Document and institutionalize an approach to managing code conflicts by establishing guidance related to what codes generally supersede other requirements (e.g., safety over aesthetics) and a process for resolving conflicts given certain conditions, to reduce staff time involved in mediations.

Revise the code development and revision process to incorporate review and discussion with other workgroups involved in the permitting process, to promote consistency and understand potential impacts to other departments.

Processes and Systems

3.

Observation The City’s current permitting processes are largely decentralized and operate in distinct siloes that can create confusion, processing delays, and an inconsistent customer experience.

Recommendation

Align leadership in support of prioritizing permitting processes and create dedicated ongoing staff time to conduct plan checks in order to foster timely reviews and interdepartmental communication.

Implement routine cross-functional meetings for key internal stakeholders in the permitting process to ensure alignment, review performance measures to improve timeliness and customer satisfaction, and proactively resolve comments or concerns in the plan check process.



OBSERVATIONS AND RECOMMENDATIONS Establish and monitor performance measures for the permit process

overall and for individual workgroups, to help hold City divisions accountable for timeliness and customer service.

Assign a project manager to each permit application in order to facilitate the application through the process, smooth interdepartmental communications, and serve as a point person for customer inquiries.

4.

Observation

The City uses multiple systems in the permitting process that require duplicative, manual entry of data by both customers and City staff. Staff are unable to provide fee estimates for customers, and there is a risk that plans are not routed to the appropriate divisions for review.

Recommendation Invest in a comprehensive permitting system that guides customers through the permit application process, eliminates the need for manual entry, and allows for customization of workflows in accordance with City requirements.

5.

Observation Staffing cuts have resulted in reliance on a limited number of key employees and ultimately, negatively impacted the ability of City employees to process permits in a timely manner.

Recommendation

Ensure every workgroup involved in plan check has at least two employees trained to complete the review required for their function.

Augment existing staffing levels through temporary employees or contracting out portions of the plan check process to enable City employees sufficient time to dedicate to process and system redesign.

Following the process and system redesign efforts, reassess employee workloads across workgroups involved in the permitting process and adjust accordingly for revised roles and responsibilities across and within divisions.

Establish a prioritized list of positions across the City to support and expedite the permitting process for customers.

6.

Observation

No comprehensive guidance or checklists for the permitting process currently exist to guide staff in their roles, and customers report inconsistencies related to customer service and code interpretations in plan check and inspection processes.

Recommendation Develop written guidance, checklists, and training to support City employees in providing a consistent experience and direction to customers.

7.

Observation Streamlining the permitting process will require significant change across a broad group of stakeholders, including City Council, leadership, and employees, as well as the community, in order to be successful.

Recommendation Leverage a change management framework to effectively engage key stakeholders, communicate the need for and impact of change, and support accountability for adopting changes.

Customer Service

8. Observation The City’s unique regulations require extended permitting timelines, elevated fees, and expensive capital outlays for customers to comply, which has a disproportionately negative impact on small businesses in the community.




Recommendation

Update the definition of small businesses in the municipal code to reflect current socioeconomic expectations and support localized economic recovery efforts.

Consider providing additional exemptions or granting funds to assist small businesses in complying with unique code requirements.

Consider expediting the permitting process and reducing associated fees for qualifying small businesses in order to support local economic recovery.

9.

Observation Customers report a perception that the City operates as a gatekeeper, rather than a facilitator, of the permitting process.

Recommendation

Develop a service philosophy for the permitting process and reframe the City’s role as a partner to the community.

Support City staff in adopting the service philosophy and cultural shift to proactively support small businesses and residential customers through the complete permitting process, by providing training and reinforcing accountability.

10.

Observation The City’s primary permitting website is not customer-centric and provides inconsistent levels of information on regulatory requirements that are challenging to find and understand.

Recommendation

Redesign the Community Development permitting website to be customer-focused and provide the appropriate resources for customers.

To improve customer service, create simplified permit guides for each type of permit using layman’s terms and include applicable requirements, anticipated response time, and estimated fees.

Consider developing video tutorials that explain City-specific requirements for frequent permit types.

11.

Observation The City currently lacks a formal customer feedback mechanism to understand how well it serves different types of customers.

Recommendation Develop and implement a simple yet meaningful process to solicit, collect, and analyze customer feedback on the permitting process to facilitate ongoing continuous improvement.



BACKGROUND, SCOPE, AND METHODOLOGY

The City of Santa Monica is experiencing unprecedented challenges due to the impacts of COVID-19. Not only has the City been required to adapt to a remote work environment, but it has also experienced significant budget reductions as a result of the economic impacts of COVID-19 on the community. At the same time, the City’s local economy, including retailers, restaurants, and hospitality providers, has suffered as a result of shelter-in-place orders and occupancy restrictions. According to Santa Monica Travel and Tourism, the destination marketing organization for the City, approximately 300 small businesses have closed as a result of the pandemic. The high volume of vacant storefronts within the City will continue to have an impact on ongoing local economic recovery efforts.

The newly formed Community Development Department works with the community to enhance the character of Santa Monica, conserve neighborhoods, provide economic opportunity for residents and businesses, and ensure the safety of the built environment. The Department performs core permitting services, including permit application intake and routing, building code plan check, planning plan check, and inspections. Depending on the type of permit, other divisions from across the City may also be involved in the permit process. These other groups include the Fire Department; Water; the Office of Sustainability and the Environment (OSE); Mobility; Public Landscape; Civil Engineering; Rent Control; and Resource, Recovery, and Recycling (RRR).

The City’s permitting process has long been a concern of the small business community, due to its complexity and length. The City has an opportunity to revise and streamline the permitting process to be more accessible to and efficient for small businesses, with the ultimate goal of supporting local economic recovery.

This study was designed to assess the economy, efficiency, and effectiveness of the City’s permitting process, led primarily by the Planning and Building and Safety divisions within the Community Development Department. Its goal is to enhance the ability to meet the needs of the community in a reduced resource environment, with a focus on:

Interdepartmental communication, coordination, collaboration, and process efficiency

Virtual and in-person customer service efficiency and effectiveness

Given the challenges currently facing the City, this study focused primarily on the permitting experience for residential property owners and small business owners in the community. Analysis was informed by employee interviews, document review, an internal staff survey, an external customer survey, small business focus groups, and research into best practices for similarly situated cities across the country. The study was conducted between December 2020 and May 2021, and consisted of four major phases:

1. Project Initiation and Management: This phase concentrated on comprehensive planning and project management, including selecting employees to interview, identifying documents to review, communicating results, and establishing regular reports on project status.



2. Fact Finding: This phase included interviews, focus groups, document review, surveys, and best practice research. We worked with department staff to obtain the most currently available information and insights.

○ Interviews: We conducted interviews with a wide range of employees from the Community Development Department (including the Building and Safety, Planning, and Economic Development divisions), Public Works (including RRR, Water, and OSE divisions), Fire, Department of Transportation (Mobility), Information Services, and the City Manager’s Office.

○ Focus Groups: We held a series of focus groups with small business owners and others in the real estate and development communities to gather feedback on permitting processes.

○ Document Review: We reviewed documents including historical permit data, municipal code, policies, procedures, organization charts, budgets, and planning documents.

○ Surveys: We conducted two surveys (internal and external) for this study. The internal survey asked City employees involved in the permitting process to provide feedback on the process as a whole and on interdepartmental collaboration and communication. This survey was conducted over the course of several weeks and received 35 responses—a 54.7% response rate. The external survey asked individuals who applied for a permit in the last three years to provide feedback on their experience with the City’s permitting process. This survey was conducted between March 2, 2021 and March 11, 2021 and received 204 responses—a 4.3% response rate.

○ Best Practice Research: Based on the opportunities for improvement identified, we conducted research to ascertain best practices found in other municipal permitting processes.

3. Analysis: This phase served as the assessment portion of the project where, based on information gathered, we evaluated the importance, impact, and scope of our observations in order to develop recommended efficiency and effectiveness changes, with the ultimate goal of supporting customer service.

4. Reporting: This phase concluded the project by reviewing draft observations and recommendations with the Department’s leadership team and City Manager’s Office to validate facts and confirm the practicality of recommendations.



COMMENDATIONS

Based on conversations with City staff and document review, it is clear that there are several commendable aspects of the current permitting processes:

Electronic Plan Review: The City implemented electronic plan submittal and review over a decade ago, which proved beneficial to the continuity of service for many types of permits during the COVID-19 pandemic. This process allows plans to be reviewed concurrently by multiple departments and divisions, and consolidates comments for the applicant.

Virtual Permit Counter: In late 2020, the Department developed and implemented a virtual permit counter for permits that were traditionally issued same day when the Permit Center was operational. This enables expedited permit approvals for simple permits and requires coordination across multiple divisions, which is ultimately led by the Community Development Department.

Virtual and Digital Inspections: The Department, as well as other departments involved in the permitting process, have explored options to conduct virtual inspections for simple items via video conferencing. This has also spurred the transition to digital inspections rather than paper-based inspections.

Expedited Permitting Processes: As a result of recent events, including civil unrest in May 2020 and business restrictions during to the COVID-19 pandemic, the Department expedited several permit processes to support the local community. Examples of permits that have been expedited include repair work in downtown corridors, alcohol permits, and temporary use of public property for outdoor dining.

Staff Resilience: As a result of the City’s budget crisis, a number of positions that support the permitting process were eliminated, both within the Community Development Department and in other departments that perform plan check. Despite these personnel reductions, staff remain dedicated to City service and have often taken on higher workloads to reduce the impact to the community. Many employees expressed gratitude and excitement around implementing lasting changes to permit processes to better support customers.

We would like to thank City staff and leadership for their participation in this study.




Based on the input gathered from interviews, document review, focus groups, and surveys as well as comparisons to best practices, we prepared a comprehensive set of observations and recommendations, which are presented in three categories: Regulatory Environment, Processes and Systems, and Customer Service. The findings and recommendations for each category are detailed below.

1. Observation The City has established regulations in alignment with community values; however, these regulations create complexity in the process for both customers and City staff.

Recommendation Establish a cross-functional committee to conduct a comprehensive permitting requirements inventory and mapping, to identify opportunities to simplify and streamline the municipal code.

The City has a reputation for being an innovative, leading local government regarding sustainability initiatives. Community values, including those related to sustainability, are reflected in the municipal code, which outlines permitting requirements for businesses of all sizes and residential dwellings such as multi-family complexes and single-family residences. Some examples of unique requirements or programs include:

Seismic Retrofit Program

Climate Action and Adaptation Plan:

○ Zero Net Carbon Buildings, including Energy Code

○ Zero Waste

○ Electric Vehicle Action Plan

○ Water Self-Sufficiency, including Water Neutrality Ordinance and Sustainable Water Master Plan

Bike Action Plan

Historic Preservation and Urban Design Requirements

Tenant Protection Program

This list provides merely a sampling of unique codes or requirements. In addition to the City’s municipal code, residential and small business customers are also subject to other regulatory organizations such as Southern California Edison, Southern California Gas, the Los Angeles County Health Department, and the Coastal Commission. Each of these agencies also has requirements, approvals, and inspections that have the potential to impact permitting processes for projects located within the City.



As a result of the multiple, unique codes within the City, plan check and inspection processes have become concurrently complex and diluted. Further complicating the requirements are differing definitions and threshold requirements set by City departments or divisions that trigger their involvement in plan check. For example, in 2017 the City Council passed the Water Neutrality Ordinance which is designed to neutralize the impact of building development on the City’s overall water demand. This Ordinance requires property owners to calculate historical water usage and offset any potential increases made through their proposed project for new construction, remodels/tenant improvements, pools/spas/water features, and landscaping. Unique requirements such as this, that detail who to involve in the plan check process and what additional permits or plans are triggered by a project, result in increased complexity, risk of involving incorrect departments, lack of transparency related to fee charges, and ultimately potential delays in permit review and issuance.

Additionally, customers and City staff noted that some existing codes do not align with City values or create undue burdens. For example, the requirement for parking does not align with the City’s values related to alternative modes of transportation that are more sustainable. Additionally, parking requirements vary based on the construction location (i.e., Downtown, Pico, Montana) and parcel use (i.e., residential, restaurant, bar, gym, medical office) which makes project planning complex. Another example commonly cited by both City employees and customers relates to RRR trash enclosure requirements. Because the City services waste management in house, it requires trash enclosures to be a certain size and maintained on-site (i.e., not in alleyways). This can require a significant amount of space, reduce the size of a business or home, and create conflicts with other code requirements (see Recommendation #2). However, City values support zero or reduced waste and therefore the traditional sizes for general refuse may not align with actual waste requirements.

Due to the high level of complexity embedded within the City’s permitting process, a cottage industry of permit expediters has grown within the region to facilitate the process on behalf of residents or business owners for a fee. This demonstrates the need to rethink the system and more equitably and effectively serve the Santa Monica community.

In order to simplify the current complexity of permitting requirements for both City staff and customers, the City should establish a cross-functional committee that includes representation from each area involved in the permitting process to conduct a comprehensive inventory of all permitting requirements and triggers. This effort should achieve the following:

Identify what elements each department currently reviews, to identify potential redundancies

Assess elements that are included in plan check or inspections, but not included in municipal code and could be eliminated from existing processes

Evaluate what level of subject matter expertise is required for the review of each element, to determine whether plan review functions could be collapsed into fewer divisions through cross-training, to potentially expedite the process and increase capacity among existing staff

Identify conflicting codes or unreasonable code requirements

Clarify triggers for different plan review requirements and other permits, including whether these triggers could be collapsed into fewer requirements to clarify the process for customers and staff

Detect differing interpretations of existing requirements that should be clarified and communicated, to create consistency

There are several inputs into the City’s permitting regulations, including State of California Building Code, community input, and City Council direction. In order to make actionable changes, City staff



require support from both the community and City Council for making changes that simplify the permitting process in alignment with local economic recovery efforts. In order to facilitate building and construction that supports small businesses and residential property owners, this work should be prioritized at a City-wide level.

Following completion of this inventory, the cross-functional team should bring potential code revisions to City Council for consideration and approval. The focus of this effort should be to reduce the complexity of the code and permitting processes through standardized definitions and triggers, while still preserving community values related to sustainability and well-being. To be effective, codes should be designed to be fair, predictable, and neutral. The codes should not be so complex and technical that a subject matter expert within the City is the only individual who can review and approve a plan for any given program or area; this not only creates bottlenecks within the permitting process but also sets applicants up to fail in the initial plan check process. Ultimately, the purpose of the code should be to provide the baseline standards for the protection of life, health, property, and public welfare.

2. Observation Due to physical space limitations on parcels, there are sometimes conflicts between existing City codes that require staff and customer involvement to resolve on a case-by-case basis.

Recommendation A. Document and institutionalize an approach to managing code

conflicts by establishing guidance related to what codes generally supersede other requirements (e.g., safety over aesthetics) and a process for resolving conflicts given certain conditions, to reduce staff time involved in mediations.

B. Revise the code development and revision process to incorporate review and discussion with other workgroups involved in the permitting process, to promote consistency and understand potential impacts to other departments.

The City is characterized by dense urban development in both commercial and residential areas. Often, parcels are relatively small, especially for the number of regulations that they are each subject to. As a result of high levels of regulation and space constraints, staff noted that there are sometimes situations where all codes cannot be upheld. For example, RRR requires trash enclosures of a specified size depending on the building use, square footage, and/or occupancy; however, the Planning division also requires a certain number of parking spots for the building depending on similar requirements. While these requirements can be architecturally adjusted for on a new build, they can pose challenges on existing buildings where both codes cannot be upheld due to size constraints. Similarly, the Planning Division does not allow cross-connection water devices in front of a building, but due to state health requirements the devices must be connected to the main water source, which is sometimes in front of the building. Staff noted similar conflicts between loading zones, visual obstruction zones, parking spots, alleyways, RRR, and sewer requirements.

Currently, code conflicts are handled on a case-by-case basis. The Planning Division often mediates conflicts with the applicant and applicable City workgroups. This requires additional time on the part



of staff and can create greater confusion and delays on the part of customers, resulting in overall inefficiencies. City staff report that they have initiated work to institutionalize an approach to managing code conflicts by providing guidance to employees, and promotes more consistent treatment of similar issues encountered when not all codes can be adhered to. While cases are often unique and may continue to require collaboration with other City workgroups and the customer to find suitable solutions, having guidance available for staff that details how the City has historically managed conflicts should promote a more efficient resolution process. These guidelines may also include priorities of codes; for example, safety measures listed in code may supersede other potential requirements.

Each department or division has authority and responsibility over specific codes. However, staff report a lack of interdepartmental collaboration and discussion when codes are revised, which can result in unintended impacts on other existing requirements and operations outside of one work group. Code revisions typically involve community input, which can result in different community groups shaping different parts of the code, contributing to an increasingly conflicting, complex regulatory environment. Codes related to one aspect of permitting, such as Building and Safety, then have the opportunity to impact other areas such as Mobility, RRR, and OSE. Despite complex interdependencies, there is not currently a process in place for work groups involved in the permitting process to review or provide input on the proposed code.

In order to identify and prevent conflicting codes and inconsistent thresholds or definitions, the City should adopt a stakeholder review process for permitting-related code revisions and development. This would provide the opportunity to identify potential issues with and impacts to operations of the proposed code across all permitting functions. The results of stakeholder review of the proposed code should be included in staff reports that are available to the community and City Council, to promote a complete understanding of the implications of code adoption. Ideally, this will help transition the City from adopting code revisions as an isolated process to a holistic process that considers the community, city values, and impacted City processes.

3. Observation The City’s current permitting processes are largely decentralized and operate in distinct siloes that can create confusion, processing delays, and an inconsistent customer experience.

Recommendation A. Align leadership in support of prioritizing permitting processes and

create dedicated ongoing staff time to conduct plan checks in order to foster timely reviews and interdepartmental communication.

B. Implement routine cross-functional meetings for key internal stakeholders in the permitting process to ensure alignment, review performance measures to improve timeliness and customer



satisfaction, and proactively resolve comments or concerns in the plan check process.

C. Establish and monitor performance measures for the permit process overall and for individual workgroups, to help hold City divisions accountable for timeliness and customer service.

D. Assign a project manager to each permit application in order to facilitate the application through the process, smooth interdepartmental communications, and serve as a point person for customer inquiries.

As noted previously, several divisions across the City are involved in the plan check process for a variety of permit types. However, most employees outside of Building and Safety have a number of other duties and obligations, which can make it challenging to prioritize plan check activities. This can contribute to delays in the permitting process; additionally, customers may reach out to the City to request an update on their plan check or try to expedite the review, which creates additional work for Permit Specialists who receive and respond to these inquiries.

Permit Specialists are responsible for responding to general customer inquiries, completing a quality check to ensure applications are complete, identifying different thresholds to guide the plan check process, assessing fees, and entering customer data into Accela and Project Dox. However, once the permit application leaves their queue and is assigned to the applicable workgroups for review, there is no longer a Department or employee responsible for shepherding the permit through the process or identifying delays. Staff report that when a customer is experiencing delays, they often try to contact someone at the City to nudge whatever Department/Division(s) have stalled the process. While the Community Development Department is often seen as “owning” the permit process, in reality the Department is dependent on the cooperation and timeliness of other City workgroups.

The input of other workgroups is critical to the plan check process due to the expertise offered in different areas across the organization; however, there should be alignment and accountability across departments to facilitate a streamlined customer experience. In the internal staff survey, less than half (41%) of respondents reported excellent or good interdepartmental coordination and fewer still (35%) reported excellent or good interdepartmental communication. This represents an opportunity for improvement—not only for customers but also for City employees involved in permitting.

INTERDEPARTMENTAL COORDINATION

3% 38% 29% 21% 9%

Excellent Good Average Poor Terrible



INTERDEPARTMENTAL COMMUNICATION

In accordance with the City’s “A Plan for the Future,” economic recovery is a key focus for the newly formed Community Development Department. However, the Department cannot embark on this goal alone; this requires cooperation and collaboration from other stakeholder departments across the City to improve the permitting process, thereby supporting the establishment of new small businesses. Ultimately, City leadership as a whole must decide that efficient permitting and customer service is a high priority in order to influence the priorities of other divisions and improve the permitting process. In order to achieve this, the City should consider the following:

Leadership alignment and support of revising permitting processes, including prioritization and dedication of staff time to plan check. For example, the Fire Department has three employees who are able to conduct plan check processes and do so during assigned dates and times during the week, which carves out time for these activities and provides consistency in turnaround times. Other departments or divisions that do not currently have this in place should consider dedicating specific time to plan check activities to proactively address customer needs. Overall, this message should come from department leadership and reinforce the importance of the City’s permitting process to the broader Santa Monica community. Additionally, if employees are able to align around a certain time or date for plan review processes, there can be a short debrief meeting on a weekly basis to resolve potential conflicts and foster interdepartmental communication about a plan.

Implement routine cross-functional meetings for key stakeholders in the permitting process to ensure alignment, review performance measures to improve timeliness and customer satisfaction, and proactively resolve comments or concerns in the plan check process. Customers often noted that some plan check comments were contradictory, which may be the result of conflicting codes noted in Recommendation #2 or confusion related to who is responsible for reviewing which components of code (see Recommendation #6). These meetings should work to proactively resolve these conflicts, review established performance measures for the permit process as a whole, and review individual workgroup data to reinforce accountability and dedication to revising the permit process.

Establish and monitor performance measures for the permit process overall and for individual workgroups, to help hold City divisions accountable for timeliness and customer service. Within the existing system, the Department is able to track which division(s) complete plan checks on time based on the permit type; this information was provided as part of this study and is included in Observation #5. However, the City does not currently use this information to hold divisions accountable for meeting plan check deadlines. In addition to monitoring timeliness, the City should also consider establishing customer service performance measures (see Recommendation #11) for divisions involved in the permitting process, from plan check to inspection. This should reinforce a service philosophy (see Recommendation #9) and promote service enhancements at the core of the recommendations included in this study.

Assign a project manager to each permit to monitor the permit application’s status in plan check and inspection processes and serve as a point-person for customer inquiries.

6% 29% 29% 21% 15%




Customers noted challenges in reaching an employee at the City who has accountability and authority over their permit application, resulting in significant frustration. Therefore, the City should assign a project manager to each permit application. In the absence of a comprehensive permitting system, this employee should set up automatic reminders when an application is approaching its due date and be responsible for nudging other divisions that have not yet conducted their review. The assigned project manager should be consistent for all plan check revisions and serve as a key contact for the customer, supporting timely inspections and scheduling. This is often a function housed in planning, but could also be assigned to a Building and Safety employee, Permit Specialist, or newly formed project manager positions. Regardless of where the project manager resides, it is imperative that other division staff acknowledge the employee’s role and responsibility and are responsive accordingly. Additionally, these positions must be adequately staffed in order to fulfill their intended role as customer liaison.

Overall, the ability to streamline the permitting process and serve the community requires cross-departmental collaboration and dedication.

4. Observation The City uses multiple systems in the permitting process that require duplicative, manual entry of data by both customers and City staff. Staff are unable to provide fee estimates for customers, and there is a risk that plans are not routed to the appropriate divisions for review.

Recommendation Invest in a comprehensive permitting system that guides customers

through the permit application process, eliminates the need for manual entry, and allows for customization of workflows in accordance with City requirements.

The City leverages five different systems, in addition to email, for permit-related purposes. These systems, including the types of permits each system is used for, are summarized in the following table.

INVENTORY OF SYSTEMS USED IN RESIDENTIAL AND SMALL BUSINESS PERMITTING PROCESSES

System Name Permit Types Notes

Accela Fire sprinklers (deferred submittals), excavation permit, offsites, temporary no parking, all building and safety permits

Requires manual entry into Accela system from .pdf forms

Project Dox All building and safety permits Requires manual entry and plan upload from Accela; routes plans for plan check

Citygrows Temporary use of public property, oversize load Part of initiative to support local restaurants during COVID-19 pandemic

HdL Prime Business licensing and other business-related permits

No integration with Accela or Project Dox



INVENTORY OF SYSTEMS USED IN RESIDENTIAL AND SMALL BUSINESS PERMITTING PROCESSES

Open Counter Permits moving to this system include excavation permits, offsites, and temporary no parking

The two primary systems used in building and construction permitting processes are Accela and Project Dox. Accela is used as the official permit record, while Project Dox routes plans to the various applicable workgroups for plan check. However, these two systems are not integrated, which requires duplicative manual entry into both systems.

Permit Specialists manually input redundant customer information submitted on the .pdf application into both Project Dox and Accela, review the plans for completeness, and assign a workflow based on the permit type and thresholds in Project Dox. Through Project Dox, plans are routed to the applicable workgroups for review. Due to code complexity, staff involved in the permitting process report that they are sometimes routed plans that do not require their review or are not routed plans that do require their review. This indicates that the workflows established in Project Dox may require revision, and Permit Specialists would benefit from clearer guidance and/or simplification of plan check requirements. In addition, permit fees are not currently assessed or accurately estimated until the end of the permit process due to the uncertainty caused by complex requirements and additional plans, permits, or fees that may be required for a project.

The use of two disparate permitting systems can impact communication among City divisions involved in the permitting process. For example, final inspections and certifications of occupancy are issued in Accela, but access to information and reporting in this system has not been optimized by user departments. This can cause challenges in providing a seamless customer experience. If a project triggers a Waste Management Plan (i.e., has a value of at least $50,000 or impacts 1,000+ square feet), customers are required to provide a Performance Security deposit to RRR that can be refunded within 30 days of project conclusion. However, RRR reports that is does not have access to reports stating that a certificate of occupancy has been issued for a project, therefore customers must be aware of the opportunity to pursue their refund. As a result, staff report that many customers forget about their Performance Security deposit, which increases the overall cost of permitting for customers and creates challenges in effectively managing these funds.

During restructuring, the Community Development Department’s dedicated Information Systems Department support position was eliminated. This position was largely responsible for facilitating changes and upgrades to Accela, the City’s primary permit system. In the absence of this support, staff report challenges in using the system to its full potential. Despite these challenges, City staff appear to be moderately pleased with the existing permitting systems, as noted in the following survey response.



How would you rate the following aspects of the City’s building permitting process, based on your experience?

PERMIT SYSTEMS EFFICACY (ACCELA, PROJECT DOX)

Staff and customers report that the user experience of the current electronic plan review application process is confusing and redundant. Customers are required to register in Citizen Access, which requires details related to the customer and permit in order to create a permit number. Then, the customer downloads a .pdf application from the City’s website, completes the application, and uploads it into Project Dox, which requires several more clicks than many customers anticipate to complete. Permit Specialists often receive phone calls asking questions about this process or the status of their application, which may not have been completed due to user interface shortcomings. This can result in significant frustration on the part of customers, in particular given the inability to provide in-person support during the COVID-19 pandemic. In both focus groups and the customer survey, customers reported significant challenges in navigating the online application process. As noted in the survey response below, over half of respondents reported that submitting plans was somewhat or very difficult. Not only does an inefficient system with a poor user interface impact customer satisfaction, it also creates additional work for customers and for City staff who respond to customer inquiries and enter information into the systems.

HOW WOULD YOU RATE THE EASE OF SUBMITTING PLANS FOR REVIEW?

The City should invest in a e-permitting system solution that incorporates permitting simplification and the process revisions noted within this report. Several comprehensive permitting system solutions now exist in the marketplace as a result of the COVID-19 pandemic and shifts to remote work for municipalities. In order to be successful, the system solution should address the following:

Integration with existing City systems

User-friendly interface with the ability to complete applications online and guide applicants through the process for their plan type

Ability to provide real-time updates to customers on their plan check status

Centralization of permitting applications and processes

Customization to meet unique City requirements, both initially and over the course of subsequent years

9% 31% 37% 14% 9%


7% 16% 14% 27% 36%

Very easy Somewhat easy Neither easy nor difficult Somewhat difficult Very difficult



Ability to review plans concurrently and add reviewers in the plan check process

Plan check comment resolution tracking

Because there are a number of City workgroups involved in the permitting process from a variety of perspectives, the cross-functional team developed as a component of Recommendation #1 should remain involved for the system selection and process work. To realize the intended benefits of a comprehensive permit system solution, is it imperative that system implementation aligns closely with process revision work and involves the appropriate stakeholders across the City. Timely engagement of stakeholders is critical for system and process design, as well as buy-in and change management. Finally, the relationship between the City’s Information Systems Department and Community Development Department must be strengthened and exhibit proactive, two-way communication for system implementation and process redesign to be successful.

System implementation and process redesign requires significant staff time and effort, especially given the cross-functional nature of permitting. Therefore, the City will need to augment existing resources temporarily in order to enable sufficient resource dedication to this process. For additional information, please see Observation #5: Staffing Levels.

5. Observation Staffing cuts have resulted in reliance on a limited number of key employees and ultimately, negatively impacted the ability of City employees to process permits in a timely manner.

Recommendations A. Ensure every workgroup involved in plan check has at least two

employees trained to complete the review required for their function.

B. Augment existing staffing levels through temporary employees or contracting out portions of the plan check process to enable City employees sufficient time to dedicate to process and system redesign.

C. Following the process and system redesign efforts, reassess employee workloads across workgroups involved in the permitting process and adjust accordingly for revised roles and responsibilities across and within divisions.

D. Establish a prioritized list of positions across the City to support and expedite the permitting process for customers.

As a result of restructuring in spring 2020, staffing levels City-wide were reduced by approximately 20%, including roles in each division involved in the permitting process and at least 16 planning-related positions in Community Development. The impact of staffing cuts has been felt across the City; as positions in other work groups were eliminated, workloads for existing staff increased and responsibilities shifted among remaining personnel. Additionally, City operations (with the exception of essential services such as Police, Fire, and Public Works) were required to transition to a remote operating model as of March 13, 2020 in response to Shelter-in-Place orders. As a result of these COVID-19 impacts, staff report extended delays in the permitting process and high



workloads. In order to evaluate these claims, we assessed the customer volume, number and type of permit applications, and the average turnaround time for the last three fiscal years (FYs 2018–2020), as shown in the following table.

Although customers were no longer able to be served in person starting March 13, 2020, only the Permit Specialists experienced an increase in call volume based on available data. This is consistent with staff reports of elevated workloads for Permit Specialists, who are responsible for responding to general inquiries and the intake of permits. Two Permit Specialist positions were eliminated during restructuring, which has likely had a detrimental impact on customer service since Summer 2020.

VOLUME OF CUSTOMERS SERVED FY2018–20

Division

FY2018–19 FY2019–20

Call Volume In-Person

Customers Served

Call Volume In-Person Customers Served*

Permit Specialist 8,221 6,791 8,882 5,000

Building and Safety

59,300 5,597 56,273 4,387

Planning 8,817 5,476 6,086 3,872

*The City’s Permitting Center was no longer operating in person as of March 13, 2020 in accordance with Shelter-In-Place restrictions.

We also evaluated the total number of new permit applications excluding applications resubmitted with plan check corrections over the last three fiscal years. Overall, the City experienced a 9% decrease in the number of new permit applications received between calendar years 2018–2020. However, major plan review for residential, commercial, and mixed-use purposes increased in all three categories; these plan reviews are larger, more complex, and typically require additional time and work groups to complete. Therefore, despite an overall decrease in the total number of new permit applications, that figure alone does not necessarily represent a reduction in workload for employees involved in the permitting process. The results of this analysis are included in the table below.

NUMBER OF NEW PERMIT APPLICATIONS BY PLAN TYPE FOR CALENDAR YEARS 2018–2020

Plan Type 2018 2019 2020 Difference (#) Difference

(%)

Res

iden

tial

No Plans 2,282 2121 1169 -1,113 -49

OTC 343 396 795 +452 132

Minor 40 413 410 +370 925

Medium 550 707 624 +74 13

Major 22 26 60 +38 173

SFR 104 99 90 -14 -13



NUMBER OF NEW PERMIT APPLICATIONS BY PLAN TYPE FOR CALENDAR YEARS 2018–2020

Total 3,341 3,762 3,148 -193 -6 C

omm

erci

al

No Plans 438 220 178 -260 -59

OTC 242 272 253 +11 5

Minor 21 159 143 +122 581

Medium 533 445 318 -215 -40

Major 21 54 60 +39 186

Total 1,255 1,152 952 -303 -24

Mix

ed U

se

No Plans 3 3 14 +11 367

OTC 2 1 9 +7 350

Minor 2 11 6 +4 200

Medium 25 24 31 +6 24

Major 9 18 33 +24 267

Total 41 57 93 +52 127

Web

Plumbing 99 40 136 +37 37

Total 4,736 5,009 4,329 -407 -9

The City’s permitting website includes estimated plan review timelines based on permit types. These timelines were used in our timeliness assessment to determine whether or not the City was meeting the expected turnaround times for initial and subsequent review for different plan types. However, this analysis does not take total time from permit application to issuance into consideration; customers report that there are often multiple rounds of review that can delay permit timelines. Staff report that applicants have a 100% failure rate on the first round of plan review, which results in multiple rounds of review prior to permit issuance. The posted turnaround times are as follows:

Plan Review Type Turnaround Time

Same-Day 1 day

Minor Plan Review ● Initial review: 5 days

● Subsequent review: 3 days

Single-Family Residential Plan Review ● Initial review: 4 weeks

● Subsequent review: 2 weeks

Medium Plan Review ● Initial review: 3 weeks




Plan Review Type Turnaround Time

Major Plan Review ● Initial review: 5 weeks


The table below shows the average number of days the City required to complete plan check for an applicant’s initial submittal of plans. On average, the City meets its published time expectations for initial plan review. One exception to this is the timeline for minor plans, which were nearly double the time expected for residential minor permit applications in FY2020. Additionally, with the exception of Major Residential plan checks, all plan check processes (regardless of purpose or size) tend to take longer to complete. For example, the turnaround for single-family residences (SFR) and medium commercial projects increased by over four days between FY2018 and FY2020.

AVERAGE NUMBER OF DAYS FOR COMPLETION OF PLAN CHECK – FIRST SUBMITTAL OF PLANS

Plan Type Time

Expectation 2018 2019 2020

Year Over Year

Difference (#)

Res

iden

tial

Minor 5 days 9.3 days 6.6 days 9.9 days 0.6

Medium 21 days 17.4 days 19.0 days 20.7 days 3.3

Major 37 days 28.2 days 37.5 days 24.9 days -3.3

SFR 30 days 23.7 days 20.5 days 28 days 4.3

Com

mer

cial



Major 37 days 23.7 days 22.4 days 23.9 days 0.2

The table below shows the average number of days the City required to complete subsequent plan check for plans that were resubmitted with corrections. Similar to initial plan review timelines, the City typically meets its established time expectations for subsequent plan reviews, with the exception of minor plans. However, plan checks tend to take longer to complete for about half of plan types, including minor residential plans, which have grown significantly more common in recent years.



AVERAGE NUMBER OF DAYS FOR COMPLETION OF PLAN CHECK – SUBSEQUENT SUBMITTALS OF PLANS

Plan Type Time

Expectation 2018 2019 2020 Difference (#)

Res

iden

tial



Major 21 days 16.9 days 14.2 days 14.3 days -2.6

SFR 14 days 13.2 days 12.6 days 13.1 days -0.1

Com

mer

cial

Minor 3 days 5.8 days 2.9 days 4.6 days -1.2


Major 21 days 13.8 days 13 days 14.1 days 0.3

While the data above demonstrates that the City frequently meets posted turnaround times, it is not holistic data from application date to approved permit. The number of subsequent reviews completed to secure an approved plan is not included in the timing analysis above; ultimately the number of reviews can stem from factors such as unclear requirements, conflicting or unclear plan check comments, or customers not correcting issues in resubmittals. Many small businesses reported that permitting requires approximately a year to accomplish, while residential customers expressed dissatisfaction in weeks or months of delay to secure a permit for minor items such as window or roof replacements. In the customer survey, the majority of respondents rated permit turnaround times, response times, and the level of communication with City employees as terrible or poor.

PROCESSING/TURNAROUND TIME

STAFF RESPONSE TIME

5% 7% 15% 18% 55%


3% 13% 18% 22% 44%




FREQUENCY OF COMMUNICATION FROM THE CITY

Without a significant change in processes and systems to increase the efficiency of permitting, delays will continue to present timeliness and responsiveness concerns. From a staffing perspective, there are several keys to supporting greater efficiency and effectiveness of the permitting process. These are detailed below.

Cross Training

Typically, departments/divisions assign plans to a team of people that can complete the plan check process. For example, the Fire Department has three FTEs who complete plan checks and inspections, in addition to a myriad of other department-specific duties. In contrast, the Office of Sustainability and the Environment (OSE) has three employees that each look at one different aspect of code: Water Neutrality, Green Building and Landscaping, and Net Zero Energy. This separation of duties can result in delays in the permitting process and challenges in responding to customer inquiries.

As a result of City restructuring, there may be workgroups involved in plan check processes where staff have absorbed these responsibilities from employees who are no longer with the City, or where the total number of employees able to complete plan check has been reduced. Each workgroup involved in the plan check process should ensure that at least two employees are able to conduct plan check for the applicable code(s) their unit is responsible for. This provides greater depth within existing staff and coverage for employee absences. Additionally, as noted in Recommendation #3, each workgroup should also consider reserving time for plan check processing, similar to the Fire Department, to ensure employees have sufficient time to regularly dedicate to these duties.

Short-Term Staffing Needs

Given the existing staff shortages, it is unlikely that this critical work can be accomplished using existing resources while also continuing ongoing permitting activities for customers. The work required to implement the recommendations in this report is urgent, aligns with economic recovery, and will require significant staff resources; consequently, the City should temporarily augment its existing staffing through limited-term employees or contracting out a portion of the work, if feasible. The City should consider adding temporary limited-term staffing to enable the time and space for existing employees to engage in recommendation implementation. These positions may include a Building and Safety Permit Specialist, Assistant Planner, and Senior Plan Check Engineer.

Alternatively, the City’s “A Plan for the Future” includes a provision that allows using supplemental contract services to ensure response times are appropriately aligned with the urgency of the situation, to help with workload increases associated with economic recovery. However, contracting this work out will require a meet and confer with the bargaining group that represents the majority of positions involved in permitting.

3% 8% 22% 24% 43%




Long-Term Staffing Needs

Throughout the municipal code, process, and system revisions noted in this report, roles and responsibilities across City departments and divisions are likely to shift. Therefore, the City should conduct a staffing level analysis based on the revised workflows to determine the appropriate level of resources given these shifts. Given the City’s limited resources, the analysis should consider how existing roles may be repurposed to meet new requirements where feasible, and a prioritized list of positions should be prepared to help fill adjusted or new roles. To guide this analysis, the City (including Community Development and other City workgroups) should consider the respective roles and responsibilities of each department and division in the permitting process, For example:

During the municipal code and process review, the City may opt to consolidate plan review functions where appropriate. These areas should be noted and staffing levels adjusted accordingly.

The employee classification responsible for adopting the project manager role for each permit application, to serve as a point person for customers with questions and usher the permit through the process, as noted in Recommendation #3. This represents new work that currently does not exist within the City’s permitting process and therefore will require additional staff capacity to perform this function.

6. Observation No comprehensive guidance or checklists for the permitting process currently exist to guide staff in their roles, and customers report inconsistencies related to customer service and code interpretations in plan check and inspection processes.

Recommendation Develop written guidance, checklists, and training to support City

employees in providing a consistent experience and direction to customers.

Workgroups involved in permitting have a wide variety of employee and customer guidance available to facilitate the plan check process. Each workgroup’s level of documentation and written guidance varies in both content and format, which may suit their unique needs. For example, some departments have requirements embedded in plan check applications, while others have additional policy and procedure guidelines for employees. Only the Mobility Division had a comprehensive checklist to support the plan check function.

Inconsistent staff guidance can create complications for the permit intake process and variations in how plan checks are performed by different employees within departments. Ultimately, inconsistency in the permitting processes increases the time to complete a project, increases costs, negatively impacts customer service, and has the potential to create gaps that could pose hazards to the community. In the employee survey, 26% of respondents reported that clarity of expectations in the permitting process was poor or terrible, with no respondents indicating this as “excellent.” Additionally, two-thirds (67%) of respondents to the customer survey reported roles and responsibilities in the permitting process as poor or terrible.



EMPLOYEE SURVEY: CLARITY OF EXPECTATIONS

CUSTOMER SURVEY: CLARITY OF ROLES AND RESPONSIBILITIES DURING THE PROCESS

Customers report significant inconsistencies in terms of code interpretations and inspection directions. This has a detrimental impact on the clarity and transparency of requirements, contributing to multiple plan resubmittals, which further delays the process. For small businesses, all delays negatively impact their financial position since typically businesses make monthly lease payments, regardless of their stage in the permitting process. Furthermore, multiple customers in focus groups expressed frustration with the City’s inspection process, citing inconsistent directions depending on the inspector assigned and incomplete information given at the time of an inspection. This causes rework and additional delays in the process to complete a project and secure a permit, whether residential or commercial. In the customer survey, approximately half of respondents reported poor or terrible consistency in plan check comments (56%) or inspection feedback (42%).

CONSISTENCY IN PLAN CHECK COMMENTS

CONSISTENCY IN INSPECTION FEEDBACK

34% 40% 20% 6%


4% 13% 16% 28% 39%


6% 12% 26% 26% 30%


8% 21% 29% 14% 28%




To ameliorate these frustrations, the City should clarify the code requirements as a component of Recommendation #1. Following this, management for each area should work with staff to provide guidance on the interpretation of code and reinforce the City’s role as a facilitator of the permitting process rather than a gatekeeper.

In addition to updating policy and procedure documentation, each workgroup should develop new or update existing checklists and criteria detailing what needs to be reviewed during pre-submittal, plan check, and inspection. These checklists will help guide staff, can be used as a comprehensive training tool, and support a reliable experience for permit applicants. Use of a checklist also removes elements of subjectivity during each portion of the permitting process, holding applicants to the same consistent standards.

7. Observation Streamlining the permitting process will require significant change across a broad group of stakeholders, including City Council, leadership, and employees, as well as the community, in order to be successful.

Recommendation Leverage a change management framework to effectively engage key

stakeholders, communicate the need for and impact of change, and support accountability for adopting changes.

The City as a whole has undergone significant change over the last year, including budget and staffing cuts and transitioning to a remote operating environment. The recommendations included within this report represent another significant change to the permitting process, which has been challenging for customers for many years. In order to achieve successful implementation of these recommendations, several key stakeholders must be engaged throughout the change process, including:

City Council and the community

City leadership

City employees involved in the permitting process

According to a survey conducted by Management Concepts, one of the primary keys to success in any change initiative in the public sector is aligning the change effort to mission-critical goals1. Therefore, the link between the permitting process and the local economic recovery efforts the City is currently focusing on should be clearly articulated to provide broad support for the change effort, in particular with City Council and the community. To support success, City leadership should define the priorities of the change initiative and intended outcomes, including performance measures to monitor progress as implementation occurs. The reason for and desired outcomes of the change should be

1 Successful Change Management Practices in the Public Sector: How governmental agencies implement organization change management https://www.govexec.com/assets/sponsored-change-management-practices.pdf



clear and agreed upon to support the City in gaining buy-in and support from the many stakeholders involved in the process.

In order to appropriately engage each stakeholder group, City leadership should create a cross-functional Steering Committee, led by a project sponsor from within the Community Development Department or the City Manager’s Office. The Steering Committee should involve stakeholders from each impacted workgroup, the City Attorney’s Office, and Information Systems Department to support a collaborative, unified effort. Employees selected for inclusion in the committee should be engaged and demonstrate a willingness to collaborate and break down existing siloes between functions. The Steering Committee should be responsible for enacting changes, monitoring progress of the change plan, and developing communication materials that provide regular progress updates to City leadership and interested employees.

The table below shows the respective roles and responsibilities of each party in the change management process required for permit process streamlining to be effective.

Stakeholder Group Roles and Responsibilities

City Council and Community

● Define permitting process streamlining as critical to local economic recovery efforts

● Provide resources as necessary to support streamlining efforts

● Provide input on proposed municipal code revisions with particular attention on the impacts of permit applicants

● Accept code revisions

City Leadership ● Establish a Steering Committee comprised of engaged representatives across involved City departments and divisions

● Define the vision and goals for permitting process streamlining, including Key Performance Indicators to monitor and communicate progress toward goals

● Demonstrate commitment and dedicate resources as required to support permitting streamlining and ongoing processes

● Communicate the need and goals for change to department staff

● Recognize staff for enacting changes consistent with recommendations

Steering Committee

● Develop an implementation plan to guide change, including timelines, roles, and report-outs

● Engage meaningfully with other Committee members to rethink historical practices

● Maintain a customer-centric focus

● Execute the implementation plan in collaboration with other City employees and third-party vendors as applicable

● Monitor and communicate progress on the implementation plan

● Develop regular communication materials for City leadership and employees

City Employees ● Demonstrate a willingness to adjust processes

● Engage in the process as requested

● Enact changes consistent with streamlining recommendations and updated processes

There are a number of frameworks the City can use to guide them throughout the change management process. Some well-known frameworks that may be effective for the City in this



particular engagement include Kotter’s 8-Step Change Model2, which involves the following components:

1. Create a sense of urgency: This step includes defining the need for change across all stakeholder groups and unifying around the intended outcomes of supporting local economic recovery, as noted above.

2. Build a guiding coalition: The Steering Committee appointed by City leadership represents the guiding coalition for this process and serves to guide, coordinate, and communicate change-related activities.

3. Form a strategic vision and initiatives: This step of change management breaks down the ultimate goal of the change into easily understood and distinct, though connected, initiatives or “steps” in the process. This may be a component of the implementation plan.

4. Enlist a volunteer army: As appropriate, Steering Committee members should engage employees within their work groups as they relate to elements of proposed change that impact them and their work, with the goal of moving everything in the same direction as established by City leadership and the Steering Committee.

5. Enable action by removing barriers: This step of the change process includes approaching the permit process with an open mind by letting go of historical practices, hierarchies, and siloed approaches to code development and plan check. This process provides an opportunity to rethink how the City serves the community with respect to permitting, while still acknowledging the subject matter expertise housed within each department and division currently involved in the process.

6. Generate short-term wins: As changes are agreed upon and improvements become apparent, the Steering Committee should communicate these results to spur additional employee engagement and motivation to change.

7. Sustain acceleration: As it becomes apparent that changes will be implemented, the Steering Committee should continue to build on its successes by demonstrating improvements and institutionalizing new processes through the system implementation, roll-out, policies, procedures, and other forms of employee and customer guidance. This may also include the development and implementation of a service philosophy (Recommendation #9).

8. Institute change: Reinforce the new expectations, such as role changes and process adoption, for City employees through performance metrics, performance evaluations, and ongoing opportunities to solicit customer feedback. At the City leadership and City Council level, report back on the Key Performance Indicators used to monitor progress toward agreed-upon goals.

The City may implement a different change management model that better suits its culture or unique needs in regard to this initiative; at the heart of any success change management initiative is the ability to engage and secure buy-in from the people involved in the process.

2 https://www.kotterinc.com/8-steps-process-for-leading-change/



8. Observation The City’s unique regulations require extended permitting timelines, elevated fees, and expensive capital outlays for customers to comply, which has a disproportionately negative impact on small businesses in the community.

Recommendation A. Update the definition of small businesses in the municipal code to

reflect current socioeconomic expectations and support localized economic recovery efforts.

B. Consider providing additional exemptions or granting funds to assist small businesses in complying with unique code requirements.

C. Consider expediting the permitting process and reducing associated fees for qualifying small businesses in order to support local economic recovery.

As noted throughout this report, the complexity and requirements established within the Municipal Code have the potential to negatively impact existing and incoming small businesses. Staff report that permitting requirements are often particularly challenging to navigate when there is a change in proposed use for an existing space, which triggers additional requirements, layers of review, time to complete the permitting process, and cost. This can be detrimental to small businesses that lack the resources to facilitate their plans through the permitting process and may have already secured a space that must be paid for while the permitting process is underway. While local regulations reflect Santa Monica community values, they can be challenging for small businesses to comply with due to elevated costs through both unanticipated fees, time to approve plans, and operational requirements established in municipal code. For example, if restaurants are required to transition to operate all-electric kitchens, there is a significant up-front expense associated with making that change to existing restaurants.

As the City focuses on local economic recovery, cost and complexity barriers have the potential to negatively impact the small business community in the City through multiple plan revisions, complexities in operating requirements, and elevated fees. Therefore, the City should consider how to create priorities and better support small businesses throughout the permitting process and the subsequent impacts of regulatory changes. For example, the City could consider granting expedited permits for qualifying small businesses and/or reducing associated fees in order to assist the establishment of new small businesses. Additionally, the City could provide short or long-term exemptions from the high-cost code requirements for small businesses, or, alternatively, provide grant funding to help locally owned small businesses comply with these unique code requirements.

Additionally, the City’s current definition of what qualifies as a small business (and what is therefore exempt from certain requirements and fees) is outdated. According to MC 6.04.025b, a small business is defined as a business operating within the City that has total taxable and nontaxable annual gross receipts of less than $40,000. In the nearby City of Los Angeles, this figure is $100,000. Given the high cost of operations within the City, most small businesses are unlikely to qualify for exemptions since they would likely not be able to maintain sufficient cash flow to be operational. To



support small businesses in the City, the municipal code should be updated to reflect the current economic environment and operating costs required to maintain a business within City limits. This should increase the number of small businesses that are eligible for tax exemptions and other forms of local financial assistance, ultimately supporting local economic recovery.

9. Observation Customers report a perception that the City operates as a gatekeeper, rather than a facilitator, of the permitting process.

Recommendation A. Develop a service philosophy for the permitting process and reframe

the City’s role as a partner to the community.

B. Support City staff in adopting the service philosophy and cultural shift to proactively support small businesses and residential customers through the complete permitting process, by providing training and reinforcing accountability.

In both focus groups and survey results, customers reported a perception that the City operates primarily as a gatekeeper rather than facilitator of the permitting process. The survey response below shows a large variation in the perceived level of professionalism and courtesy of administrative and counter staff; nearly every possible category shares approximately 20% of responses, with a higher concentration of respondents reporting this as “good” or “average.” Responses to the customer perception of staff knowledge and helpfulness are similarly distributed, with a larger concentration of respondents reporting their experience as “terrible” or “average.”

PROFESSIONALISM AND COURTESY OF ADMINISTRATIVE AND COUNTER STAFF

STAFF KNOWLEDGE AND HELPFULNESS IN HANDLING YOUR PERMIT APPLICATION AND QUESTIONS

Given the City’s history of strong economic success, customers reported feeling that they were at the whim of the City with little recourse apart from escalating concerns up the chain of command. Now

18% 26% 24% 17% 15%


12% 22% 23% 18% 25%




that the City has experienced financial hardships both internally and across the community, the relationship between the City’s financial success and the local business community’s success has been made clearer. Staff report significant turnover of small businesses as a result of COVID-19 restrictions; if the City wishes to replace these businesses with other independently owned small businesses, it will need to adopt a service philosophy that centers around the customer and guides them through the process.

Several other cities have created service philosophies specific to the permitting process; some examples are provided below:

City of Lacey, Washington: “Our philosophy is to provide assistance as early as possible in the design process to facilitate the application review process, to make your project viable, efficient, and cost-effective, while meeting all of the mandated code requirements.”

Garden City, Georgia: “…Our philosophy is to continuously provide open communication and responsiveness during the review process of all permit applications. Although the mechanisms and procedures to ensure compliance with applicable codes, permits, and regulations can be cumbersome and complicated, they do not have to be open-ended and unclear for developers, consultants, contractors, and property owners.”

City of Santa Clarita, California: “Fairness, equality, and the highest standard of professional ethics are our goal in providing our services to the community. The successful completion of your project is important to the City of Santa Clarita, and we will work closely with you toward that end.”

The Steering Committee, with support from City leadership, should develop a permit service philosophy that defines how the City intends to serve its customers. This philosophy should represent a shift required to support local economic recovery efforts, with particular focus on small businesses to consequently reinvigorate economic activity. Additionally, City leadership should integrate the service philosophy into the processes and interactions staff have with customers. This can be done through trainings and would ideally be incorporated into employee performance appraisals for accountability purposes.

10. Finding The City’s primary permitting website is not customer-centric and provides inconsistent levels of information on regulatory requirements that are challenging to find and understand.

Recommendation A. Redesign the Community Development permitting website to be

customer focused and provide the appropriate resources for customers.

B. To improve customer service, create simplified permit guides for each type of permit using layman’s terms and include applicable requirements, anticipated response time, and estimated fees.

C. Consider developing video tutorials that explain City-specific requirements for frequent permit types.



Given the level of complexity involved in the City’s permitting process, customers require clear guidance on requirements. Several years ago, the Building and Safety Division developed cover sheets for each unique permit type that provide links to the Municipal Code or department webpages. There are often eight to ten different City departments and divisions involved in the permitting process, but the City currently lacks a standardized mechanism to communicate City-specific requirements to customers. For example, some links are to the Municipal Code chapter that details many specific requirements for different building types, while others are links to other City webpages that may have a subsequent link to customer guidance. This presents significant challenges for both small business and residential customers who are not as familiar with permitting or construction/architectural jargon. Rather than providing all relevant requirements for a specific type of customer or permit, the customer must seek the information from a variety of sources that present information differently. As noted previously, staff report that the City has a 100% failure rate on the first round of plan review, which indicates the need for customer education in order to support their success.

The Community Development Department website contains a significant amount of information, but is organized by division rather than from the customer lens. There are currently over 40 project types listed on the website and matrices that link information related to what plan elements are required, the timelines for review, and the requirements each project type is subject to. Notably missing from each plan type is a fee estimate for the permit, which can also cause alarm for customers when they submit plans and again at the end of the process when the permit is issued. In the customer survey, 57% of respondents reported the availability of relevant information on the website as poor or terrible, indicating a need for an enhanced user experience.

AVAILABILITY OF RELEVANT INFORMATION ON THE WEBSITE

As part of the permit streamlining process, the Steering Committee should develop a standardized template for customer handouts and guides for each permit type. Departments and divisions responsible for checking each area of code should draft guidance to customers and include references to applicable codes, fees, and regulations. To support understandability and transparency, technical employees should work with an editor to relay requirements in a way that is customer friendly. Ultimately, these guides should provide consistent and complete information for customers.

In addition to posting these guides on the City’s permitting website, the Community Development Department should work with the Information Systems Department to redesign the website to be customer centric. This includes creating a webpage that is easy to navigate, understand, and retrieve information from. There can be webpages for different permit types that include customer guides, FAQs, fees, and potentially a video tutorial to relay any unique City requirements for that permit type. This all promotes accessibility to information for customers and will hopefully reduce the number of

3% 11% 28% 26% 32%




questions routed to Permit Specialists about the process, thereby increasing efficiencies for both customers and City staff.

11. Observation The City currently lacks a formal customer feedback mechanism to understand how well it serves different types of customers.

Recommendation Develop and implement a simple yet meaningful process to solicit,

collect, and analyze customer feedback on the permitting process to facilitate ongoing continuous improvement.

Currently, the City lacks a formal customer feedback mechanism to understand customer pain points and evaluate overall satisfaction. In lieu of this data, staff interviewed for this study reported anecdotal information about the shortcomings of the permitting process and customer hardships. However, this information was not collected or shared in a way that spurred significant changes in the process, and often resulted in managerial intervention to push a permit application through the process. Anecdotal information shared with Moss Adams was echoed in the small business owner focus groups and the customer survey (included in Appendix B).

Community Development staff should work with permitting staff involved in daily operations to identify a realistic and meaningful way to request, collect, and analyze feedback from customers on their experience in the permitting process. This could be a short survey sent at the end of certain types of permit activities to understand what worked well and what, if anything, the customer would like to improve. Alternatively, the Department could conduct a survey of all permit applicants on a regular (annual or biannual) process to solicit feedback and track progress on customer satisfaction.

A mechanism for feedback should focus on specific, actionable items that are within the City’s power to change. Community Development should conduct an interdepartmental work session to identify what elements of the permitting process could benefit from feedback and customer experience evaluations, structure the feedback to be collected in a way that allows staff to easily collect the data, and transform the data into useful information that can clearly identify both positive feedback and potential opportunities for improvement.

The feedback process should be easy and relatively short, and provide data that gives clear and meaningful guidance. Creating a feedback loop with permit applicants will enable the City to more precisely identify potential opportunities for improvement, proactively address emerging pain points, monitor progress on customer satisfaction (potentially using the customer survey included in this report as a baseline), and empower City staff to make meaningful, data-driven decisions.

All workgroups involved in the permitting process should convene on a quarterly basis to review survey results and identify potential improvements to the process. This will support customer and City success and promote a culture of continuous improvement.



APPENDIX A: EMPLOYEE SURVEY RESULTS An employee survey was sent out to City employees involved in the permitting process and was open for submission from February 8, 2021 through March 8, 2021. Out of the 64 employees invited to take the survey, 35 individuals submitted either full or partial responses (a participation rate of 54.7%).

Survey respondents included representatives from the following City departments/divisions:

HOW WOULD YOU RATE THE OVERALL EFFICIENCY OF THE CITY’S CURRENT PERMITTING PROCESS?

29%

26%

13%

8%

6%

6%

3%

3%

3%

3%

87%

92%

94%

94%

97%

97%

97%

97%

Community Development - City Planning

Community Development - Building and Safety

Public Works - Office of Sustainability and the Environment

Public Works - Resource, Recovery, and Recycling

Big Blue Bus - Mobility

Public Works - Water

Fire

Public Works - Civil Engineering

Rent Control Agency

Other

No

14% 57% 20% 9%

Extremely efficient Very efficient Moderately efficient Slightly efficient Not efficient at all



How would you rate the following aspects of the City’s building permitting process, based on your experience?

PERMIT SYSTEMS EFFICACY (ACCELA, PROJECT DOX)

CLARITY OF EXPECTATIONS

REASONABLENESS OF TURNAROUND TIMES

INTERDEPARTMENTAL COORDINATION

9% 31% 37% 14% 9%


34% 40% 20% 6%


6% 40% 25% 23% 6%


3% 38% 29% 21% 9%




INTERDEPARTMENTAL COMMUNICATION

In the survey, employees were asked to rate their experience with other City departments/divisions as it relates to the permitting processes. The department/division that each employee reports to was excluded from their survey questions (i.e., an employee from Building and Safety was not able to provide a response about their experience working with the Building and Safety division).

Community Development - Building and Safety

CUSTOMER SERVICE

COMMUNICATION

TIMELINESS

6% 29% 29% 21% 15%


17% 54% 25% 4%


12% 44% 36% 8%


13% 41% 42% 4%




RESPONSIVENESS

Community Development – City Planning

N=20

CUSTOMER SERVICE

COMMUNICATION

TIMELINESS

RESPONSIVENESS

13% 42% 38% 8%


26% 26% 32% 5% 11%


15% 35% 30% 10% 10%


1% 45% 37% 7% 10%


15% 40% 25% 10% 10%




Fire

CUSTOMER SERVICE

COMMUNICATION

TIMELINESS

RESPONSIVENESS

Public Works – Resource, Recovery, and Recycling

CUSTOMER SERVICE

19% 50% 25% 6%


25% 44% 25% 6%


25% 44% 31%


24% 38% 38%


6% 18% 35% 35% 6%




COMMUNICATION

TIMELINESS

RESPONSIVENESS

Public Works – Office of Sustainability and the Environment

CUSTOMER SERVICE

COMMUNICATION

17% 17% 22% 44%


11% 39% 39% 11%


11% 39% 33% 17%


14% 43% 21% 7% 15%


13% 53% 14% 7% 13%




TIMELINESS

RESPONSIVENESS

Public Works – Water

CUSTOMER SERVICE

COMMUNICATION

TIMELINESS

13% 33% 41% 13%


13% 47% 26% 7% 7%


18% 64% 9% 9%


18% 55% 9% 18%


18% 55% 9% 18%




RESPONSIVENESS

Public Works – Civil Engineering

CUSTOMER SERVICE

COMMUNICATION

TIMELINESS

RESPONSIVENESS

18% 55% 9% 18%


16% 53% 21% 5% 5%


24% 51% 10% 5% 10%


20% 45% 25% 5% 5%


33% 43% 14% 5% 5%




Public Works – Public Landscape

CUSTOMER SERVICE

COMMUNICATION

TIMELINESS

RESPONSIVENESS

Big Blue Bus-Mobility

CUSTOMER SERVICE

18% 64% 18%


25% 58% 17%


25% 58% 17%


25% 58% 17%


50% 34% 8% 8%




COMMUNICATION

TIMELINESS

RESPONSIVENESS

Rent Control Agency (External)

CUSTOMER SERVICE

COMMUNICATION

38% 46% 8% 8%


46% 39% 15%


46% 38% 8% 8%


30% 40% 20% 10%


20% 50% 30%




TIMELINESS

RESPONSIVENESS

10% 60% 20% 10%


40% 30% 30%




APPENDIX B: CUSTOMER SURVEY RESULTS A customer survey was sent out to individuals and businesses that applied for a permit in the last three years. The survey was open for submission from March 2 through March 11. Out of the 4,784 applicants invited to take the survey, 234 applicants submitted either full or partial responses (a participation rate of 4.3%).

Which of the following best represents your role?

In your most recent permitting experience with the City of Santa Monica, did you request a permit for a residential or commercial project?

31%

35%

34%

69%

65%

66%

Property Owner

Contractor

Agent

No

Residential81%

Commercial19%

PROJECT TYPE



Which of the following best describes the residential project?

Which of the following best describes the commercial project?

Examples of “other” include:

Tenant improvement

EV charger

Solar PV system

In your most recent experience with the City of Santa Monica, what kind of permit did you apply for?

30%

2%

48%

14%

6%

70%

98%

52%

86%

94%

Multifamily

New multifamily

Existing single family

New single family

Other

No

16%

47%

3%

34%

84%

53%

97%

66%

Open a new business

Permit related to anexisting business

New building

Other

No

33%

49%

5%

1%

12%

67%

51%

95%

9%

88%

Single trade construction permit

Combo trade construction permit

Solar photovoltaic permit

Electric vehicle service equipment permit

Other

No



How did you apply for the permit?

On average, how often have you interacted with the City of Santa Monica related to permitting (applying for permits, plan reviews, inspections, etc.) in the past year?

Electronic Plan Review

77%

Over the counter permit

23%

APPLICATION PROCESS

26%

26%

19%

29%

74%

74%

81%

71%

Weekly

Monthly

Quarterly

Once or twice a year

No



How would you rate the following, based on your overall experience with these services?

PROCESSING/TURNAROUND TIME

CLARITY OF ROLES AND RESPONSIBILITIES DURING THE PROCESS

FREQUENCY OF COMMUNICATION FROM THE CITY

AVAILABILITY OF RELEVANT INFORMATION ON THE WEBSITE

5% 7% 15% 18% 55%


4% 13% 16% 28% 39%


3% 8% 22% 24% 43%


3% 11% 28% 26% 32%




STAFF RESPONSE TIME

CONSISTENCY IN PLAN CHECK COMMENTS

CONSISTENCY IN INSPECTION FEEDBACK

PROFESSIONALISM AND COURTESY OF ADMINISTRATIVE AND COUNTER STAFF

STAFF KNOWLEDGE AND HELPFULNESS IN HANDLING YOUR PERMIT APPLICATION AND QUESTIONS

3% 13% 18% 22% 44%


6% 12% 26% 26% 30%


8% 21% 29% 14% 28%


18% 26% 24% 17% 15%


12% 22% 23% 18% 25%




During the permitting process many City Departments are often involved in plan review and inspections. How would you rate your experience with each review group?

COMMUNITY DEVELOPMENT – BUILDING AND SAFETY

COMMUNITY DEVELOPMENT – PLANNING

FIRE

PUBLIC WORKS – RESOURCE, RECOVERY, AND RECYCLING

7% 21% 23% 19% 30%


7% 20% 23% 31% 19%


17% 33% 23% 13% 14%


9% 20% 31% 15% 25%




PUBLIC WORKS – OFFICE OF SUSTAINABILITY AND THE ENVIRONMENT

PUBLIC WORKS – CIVIL ENGINEERING

PUBLIC WORKS – PUBLIC LANDSCAPE

BIG BLUE BUS – MOBILITY

7% 21% 31% 24% 17%


8% 20% 31% 17% 24%


7% 32% 17% 21% 23%


7% 27% 32% 16% 18%




HOW WOULD YOU RATE THE EASE OF SUBMITTING PLANS FOR REVIEW?

How would you rate the following statements?

TURNAROUND TIME FOR INITIAL PLAN REVIEW

TURNAROUND TIME FOR SUBSEQUENT PLAN CORRECTION SUBMISSIONS

RESPONSIVENESS OF PLAN REVIEWERS

7% 16% 14% 27% 36%


6% 11% 11% 16% 56%

Timely As expected Neither expeditious nor delayed Somewhat delayed Very delayed

6% 11% 12% 19% 51%

Timely As expected Neither expeditious nor delayed Somewhat delayed Very delayed

6% 17% 24% 27% 26%

Very responsive Usually responsive Sometimes responsive Hardly responsive Never responsive



IF A CORRECTION NOTICE WAS ISSUED FOR YOUR PLAN REVIEW, WERE THE CORRECTION COMMENTS CLEAR AND

CONCISE?

ARE INSPECTIONS PERFORMED PROMPTLY AS SCHEDULED?

How would you rate the following statements?

EASE OF SCHEDULING AN INSPECTION

AVAILABILITY OF BUILDING INSPECTORS WHEN YOU NEED INFORMATION

59% 41%

Yes No

51% 42% 7%

Always Sometimes Never

29% 22% 29% 11% 9%


18% 19% 30% 25% 8%

Very available Usually available Sometimes available Hardly available Never available



IF A CORRECTION NOTICE WAS ISSUED FOR YOUR INSPECTION, WERE THE CORRECTION COMMENTS CLEAR AND

CONCISE?

67% 33%

Yes No

permitting efficiency study

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