HomeMy WebLinkAboutStaff Report 2310-21932. Staff Recommends the Policy and Services Commitee Recommend the City Council Accept the Status
Update of the Audit of the Building and Permit Review Report
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Policy & Services Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: November 14, 2023
Report #: 2310-2193
TITLE
Staff Recommends the Policy and Services Committee Recommend the City Council Accept the
Status Update of the Audit of the Building and Permit Review Report
RECOMMENDATION
Staff recommends the Policy and Services Committee recommend the City Council accept the
status update of the Audit of the Building and Permit Review Report.
BACKGROUND
Baker Tilly, in its capacity as the Office of the City Auditor, performed an assessment of the
Planning and Development Services (PDS) building permitting process. On June 20, 2022, the
City Auditor issued the Building Permit and Review Report1 with three main audit objectives:
1) Identify the highest impact areas to focus (e.g. specific permit type(s), specific sub-
processes, etc.).
2) Document corresponding process(es) and evaluate for efficiency and effectiveness.
3) Benchmark operational performance against industry practices and established
standards.
Although the audit summary contained fifteen (15) recommendations, the detailed report
provided an expanded list of seventeen (17) actionable recommendations. PDS will be
responding to and providing an update on the expanded list of recommendations.
ANALYSIS
As reflected below and on the Attachment, 9 of the 17 recommendations are now complete,
with the remainder in progress or not yet started. Over the last year, Planning and
1https://www.cityofpaloalto.org/files/assets/public/v/2/city-auditor/reports/oca-4.9-building-permit-process-
review.pdf
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Development Services has been focused on three key areas for improvement at the
Development Center: Staffing Model; Technology and Customer Accessibility of Information;
and, Process, Training, and Operations. Each of these areas are interwoven throughout the
building permitting process and updates to these areas collectively address multiple
recommendations and findings articulated in the Building Permit and Review Report.
Staffing Model
Impacts of the pandemic required PDS to restructure the staffing models of two program areas,
building inspection and building plan review. Prior to Covid-19, the building inspection program
was supported by 50% staff and 50% consultants, and the building plan review program was
100% contracted out to consultants. PDS was challenged with limited consultant availability and
high turnover, which resulted in long inspection lead times and delayed turnaround times on
plan reviews. By the end of 2022, staff met with all eight on-call consultant firms to better
understand the inability for Palo Alto to secure consultants. These meetings confirmed that
across the industry, there was a limited supply of experienced and qualified consultants in the
field. Retirees who contributed to the consultant workforce fully retired. Many consultants
relocated due to the availability of remote work. Inspectors and plan review engineers were
able to be selective in the jurisdictions they were employed in. Previous consultants and staff,
who were willing to make the long commute, were no longer required to. In FY2022 and
FY2023, PDS was experiencing a higher rate of attrition for both consultants and staff compared
to the rate of hiring.
To remedy these challenges and enable the Development Center to maintain a minimum level
of service, PDS implemented the following changes to transition the building inspection
program to a 100% in-house staffing model and the plan review program into a hybrid model:
•Added 2.0 FTE Building Inspector Specialists and 2.0 FTE Plan Check Engineer in the
FY2023 and FY2024 operating budget.
•Collaborated with a consultant to hire part-time trainee inspectors to invest into a
pipeline for future recruitments and augment staffing levels to increase inspection
availability at times of peak volume.
•Created two new classifications, Senior Building Inspector and Senior Plan Review
Engineer, for market competitiveness, succession planning, and retention.
•Reclassed all 8.0 FTE Building Inspector Specialists to Senior Building Inspectors and 2.0
FTE Plan Check Engineer to Senior Plan Check Engineer to allow the department to be
nimble in recruitment strategy and flexibility in responding to attrition.
•Reallocated temporary part-time administrative support as an HR liaison to expedite
PDS recruitments.
These actions have resulted in the restoration of inspection availability within 48 hours of a
request and the reduction of late plan reviews. In FY2022, the average rate of on-time building
plan reviews was 80%. In FY2023 and Q1‘24, these rates increased to 86% and 92%,
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respectively. Additionally, current staffing levels have restored the inspection staff‘s capacity to
invest time in training beyond maintaining minimum certifications. As of October 2023, there is
one vacant building inspector position and one vacant plan review engineer; both recruitments
are underway and will likely be filled by the end of the calendar year.
Changes to the staffing and consultant model complete six of the seventeen (17)
recommendations. PDS will continue to revisit this service model to ensure it is sustainable and
will adjust as necessary based on shifts in the industry. PDS will also be conducting a request for
proposals for development services on-call providers to update and expand the list of available
consultants in 2024.
Technology and Customer Accessibility of Information
PDS has continued to explore technology enhancements and better platforms to increase
communications with applicants and streamline the application process. The reliance on
technology continues to grow, especially with the transition to hybrid, virtual and in person
service offerings. Throughout the last year, PDS has been evaluating the use of technology and
the accessibility of guidance and resources through the application process.
There are three main platforms that enable the permitting process: Online Permitting System
(OPS/Accela), Accela Citizen Access (ACA), and DigEplan.
•OPS/Accela is the software used by staff to process permits internally by documenting
the workflow, storing documents, processing fees, and managing inspections.
•ACA is the main online permitting system that allows applicants to submit applications,
check on statuses, respond to comments, download plans and permits, and schedule
inspections.
•DigEplan is the electronic document review (EDR) software that allows staff to markup
digital plans during the review process. This system integrates the comments into
Accela for online permitting services.
The audit recommends OPS and ACA be updated to become more intuitive and incorporate
relevant information; however, PDS is limited in its ability to customize the user interface as it is
a third-party provider. Staff has simplified the information on the ACA main page and created
newly released navigation guides to assist users in the application process. Staff is currently
working on digitizing data collection by creating a fillable embedded form within OPS.
Additionally, in the first half of 2023, PDS completed a request for proposals for an EDR
software to evaluate for the best available technology. As noted in the management action
plan, DigEplan was set up on an urgent basis to respond to the pandemic and allow for
continuity of services; a contract will be presented to Council in November 2023. PDS is also
exploring third party vendors who can improve the existing user interface of ACA and embed a
wizard to guide applicants through the process. Implementation of these changes are
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anticipated to extend beyond the timeframe of the audit update as new technology will need to
be procured, customized and implemented.
PDS designed and released a new webpage2 to "Apply for a Permit” in July 2023 that provides
better guidance and increases visibility of relevant information to applicants. Staff created
customized step-by-step instructions for each permit type and published simplified submittal
checklists to provide clarity in application requirements. Staff also further promoted
appointment availabilities throughout the webpages to encourage applicants to make an
appointment for assistance. If an application is not accepted, project coordination staff are also
proactively calling applicants to offer assistance. This has resulted in clearer communications
and instructions for applicants and improved user access.
Lastly, where able, staff leveraged technology to increase automated and instant permit types.
In collaboration with the National Renewable Energy Laboratory (NREL) and the alternative
energy industry, Palo Alto initiated the SolarAPP+ pilot program in April 2022 to automate
code-compliance review for most residential roof-top photovoltaic (PV) projects with select
experienced PV installers. In September 2023, PDS expanded the SolarAPP+ program to include
both qualifying PV-only and combination PV and Energy Storage System (ESS) projects in an
effort to reduce processing times for applicants. SolarAPP+ is now available to all contractors
with qualifying projects. PDS also published a new instant permit process for Residential Heat
Pump Water Heaters in January 2023 and are currently working to include Heat Pump
Mechanical Residential Replacements and Residential Bath and Kitchen Remodels (like for like)
by June 2024.
Although these changes have addressed five of the seventeen recommendations, PDS has
identified one as complete and four as in progress because exploring technology and improving
the user interface and information accessibility is an ongoing process. As the department
continues to leverage technology to improve services, updates will be included in the next
iteration of progress reporting.
Processes, Training, and Operations
PDS internally reviewed the application process from both the customer and staff processing
perspective and have implemented changes to improve quality control, increase
communications with customers, simplify the application process, and invest in employee
training for better service delivery.
To streamline the application process and improve communication with customers, PDS
created simplified checklists for application submittal and increased internal communications
on plan review deadlines. Previously ranging from 2-15 pages, requirements have now been
reduced to 1-2 pages and provide clear and consistent expectations of application acceptance
2 https://www.cityofpaloalto.org/Departments/Planning-Development-Services/Development-Services/Apply-for-
a-Permit
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or rejection, eliminating the need for pre-application reviews and routing. Once an application
is accepted and routed internally, staff receive notifications for pending reviews in two places,
the ACA task list by due date and an email. In August 2022, staff also developed a pending and
late reviews internal tracking system for building permits and pre-applications to provide the
Development Center Permit Manager further visibility into the application process and enable
the manager to proactively coordinate with internal partners on their reviews.
During summer 2023, PDS conducted an appointment pilot program to understand when an
appointment would be most helpful and impactful to customers. Although both virtual and in
person appointments are available daily, they are not required. The results of the appointment
pilot informed the department that not all customers want to meet and those who are familiar
with the process prefer to process their application online; however, there are applicants who
may be new to the process or have complex projects who and would benefit from a required
appointment. At this time, staff are working on optimizing appointments and exploring
requiring appointments for certain types of applications to help customers navigate the
application process more effectively and efficiently.
The department has also prioritized training to improve the quality-of-service delivery.
Previously impacted by limited staff and consultant availability, the implemented structural
changes created capacity for building inspectors and plan reviewers for training beyond the
minimum requirements to maintain certifications. Both staff and the community benefit from
the expansion of knowledge and expertise of technical staff, who are responsible for
community life safety. To improve quality control, all project coordination staff have attended a
training for “How to Properly Screen Plans for Successful Permit Services” by the California
Building Officials. PDS is also focused on expanding training beyond technical skills and held a
mandatory department-wide two-part training on customer service, “Staying Courteous Under
Pressure” by Public Sector Excellence. The first session was held in October and the next session
will occur early 2024. Continual investment in staff will provide a higher caliber of service
delivery and aid in the retention of experienced employees.
Of the remaining six recommendations, two have been completed and three are in progress
through the actions above. The outstanding recommendation that has not been started is
developing a PDS strategic plan. As noted in the action plan, the department is continuing to
implement changes to permitting operations and service delivery. A strategic plan can begin in
about one year; the completion of the plan and report to Council can be expected in about two
years.
Over the last year, the Department has made significant strides in improving service delivery at
the Development Center. These incremental changes impact all areas of operations and require
thoughtful execution. The department has also been precluded in advancing the
recommendations in this audit due to vacancies in key positions across all program areas. One
more notable position is the Assistant Chief Building Official, added in July 2022, intended to
lead the implementation of audit recommendations, establish interdepartmental workflows,
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and provide strategic direction on complex operational change and policy. This position has
been vacant since its approval, and the department is currently evaluating the position
classification to align with the market after an unsuccessful recruitment.
In the next year, PDS will continue to prioritize the implementation of the audit
recommendations and further focus on customer service through developing internal
dashboards for better performance tracking, increasing survey responses by expanding
outreach, and leveraging technology to better integrate data into existing platforms for an
optimal user experience.
For detailed responses to each of the seventeen recommendations, refer to Attachment A. In
the interest of time, staff is providing this update to report to the Committee and public about
the status of this important work. Staff is in the process of reviewing this information and
status of recommendations with AUD for final close-out of the items staff believes have been
sufficiently addressed.
FISCAL/RESOURCE IMPACT
Resource requests to support the audit recommendations have been included in the FY 2024
operating budget. If further resources are required, Planning and Development Services will
include these requests in the annual budget appropriation process.
ATTACHMENTS
Attachment A: Status of Audit Recommendations
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
1
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: The lead time for a building inspection is approximately two weeks from request to inspection.
Hire an additional Inspector to help improve and
maintain lead times. An additional staff member would
also help support the requirement for Inspectors to meet
continuing education requirements (100 hours per year
per inspector) and keep up with changes in the building
industry.
PDS Concurrence: Agree
Target Date: Ongoing / October 31, 2022
Action Plan:
PDS is seeking two new inspector positions
as part of the FY22-23 budget and is
currently recruiting for these two new
inspector positions using City Manager
authorized over-strength positions.
Complete Management Update October 2023:
PDS has restructured this program to
maintain a minimum level of service
and lead times. In the FY2023
Adopted Operating Budget, PDS
added two new inspector positions. In
FY2024, PDS developed a new
classification, Senior Building Inspector
and reclassified all 8.0 existing
positions to reduce turnover, aid in
succession planning, hire more
flexibility, and create a path to be
nimble and responsive to attrition.
In addition, PDS collaborated with a
consultant to hire part-time trainee
inspectors to invest into a pipeline for
future recruitments and augment
staffing levels to increase inspection
availability at times of peak volume.
It is important to note that the building
inspection program is susceptible to
increased wait times when multiple
staff are out of the office for approved
leave (sick, worker’s compensation,
vacation, etc.). The department is
proactively managing though training
and utilizing part time consultant
inspectors when available.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
2
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Find additional efficiencies with current staff, including
assigning geographic areas to Inspectors to reduce
travel time and possibly assigning inspections by
specialty
PDS Concurrence: Partially Agree
Target Date: Ongoing / October 31, 2022
Action Plan:
To the extent feasible, this already occurs.
Challenges arise however depending on the
type of inspection needed and if that requires
an inspector with a certain skill-set or
specialty. It is anticipated with the addition of
two additional inspectors and consultant
funding requested in the FY22-23 budget,
combined with existing efforts to assign
inspections based on geography, the
department will be able to restore more
timely inspections schedules.
Complete
Management Update October 2023:
Inspection times have been restored to
availability within 48 hours when fully
staffed as a result of the actions
articulated above. As noted in the
action plan, this already occurs but skill
set and specialty are key factors in
daily assignments.
If lead time lengths persist after hiring of additional
inspector, PDS should renew efforts to utilize contract
inspectors to assist with peak application times. As part
of this, PDS should expand the pool of contract
Inspectors it can rely on that are versed in City building
code or find ways to utilize contract staff for Inspections
that are not as heavily modified per City building code.
PDS Concurrence: Agree
Target Date: October 31, 2022
Action Plan:
PDS is proactively seeking a two additional
inspectors. As part of the FY22-23 budget,
PDS is also requesting additional consultant
funds to bring in inspectors to manage
increased workload or respond to staff
absences. Moreover, staff is reviewing its
contracts with venders to ensure Palo Alto
remains competitive with other jurisdictions.
Complete Management Update October 2023:
Inspection times have been restored to
availability within 48 hours when fully
staffed as a result of the actions
articulated above. In addition, PDS will
be conducting a request for proposals
in CY2024 to update and expand the
pool of available on-call development
services consultants for inspection and
plan review services
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
3
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Consider third party plan review and inspection options
with applicants paying a premium fee for expedited
review (certified by the City, with a fees/premium price to
the applicant to ensure no cost to City, and establish a
quality assurance process).
PDS Concurrence: Partially Agree Target
Date: October 31, 2022 Action Plan:
If the above actions do not sufficiently address
the delay in inspection services, staff will
consider this recommendation as a
contingency to address continued delays. It is
worth noting this recommendation adds some
complexity to the operation and additional staff
resources to manage which may draw
attention away from other efforts.
Complete
Management Update October 2023:
Inspection times have been restored to
availability within 48 hours when fully
staffed as a result of the actions
articulated above.
To address plan review lead times, In
FY2023 and FY2024, PDS added a
total of 2.0 FTE Plan Review
Engineers. One of those vacancies
have been filled and the second
vacancy is expected to be filled by the
end of the year.
PDS also created two new
classifications, Senior Building
Inspector and Senior Plan Review
Engineer, for market competitiveness,
succession planning, and retention.
Consider the role of a lead inspector/field supervisor to
help with training, quality control, and other duties that
would assist inspection manager
PDS Concurrence: Agree
Target Date: March 31, 2023 Action
Plan:
Staff will coordinate with Human Resources to
conduct a classification review to evaluate the
scope of work for the position and determine
the appropriate level within the organization
structure.
Complete
Management Update October 2023:
In February 2023, as part of the
midyear budget, Council approved two
new classifications: Senior Building
Inspector and Senior Plan Review
Engineer. Both classifications are
pending formal approval by SEIU and
Council. PDS expects adoption by the
end this year and will be releasing an
internal promotional opportunity for a
lead inspector to assist with training,
daily route assignments, and other
duties in support of the Building
Inspection Manager. This additional
capacity would allow the manager to
also participate in more quality control
in the field and advance succession
planning and retention of experienced
staff.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
4
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: Customers/applicants need better information on all aspects of the permitting and inspection process.
The OCA recommends that PDS takes steps to ensure
that all relevant building codes, compliance guides,
checklists, videos and other process
requirements/documentation are current, visible, and
readily accessible on-line.
PDS Concurrence: Agree
Target Date: Ongoing / June 30, 2023 Action
Plan:
Staff will update recommended documents,
organize information succinctly on webpage,
reference documents throughout the permitting
process and coordinate with other City
departments to do the same. The department
will also prepare a FAQ section on the
website.
In Progress Management Update October 2023:
PDS designed and released a new
webpage to "Apply for a Permit” in
July 2023 that provides better
guidance and increases visibility of
relevant information to applicants.
Staff created customized step-by-step
instructions for each permit type and
published simplified submittal
checklists to provide clarity in
application requirements.
Staff is currently updating detailed
checklists and developing inspection
guidelines to reflect the newly adopted
code in January 2023.
Finding: A number of the forms, guidelines, and checklists provided on PDS’s website date from prior use of the OPS system.
The OCA recommends modifying OPS to
incorporate relevant information and present in more
intuitive format.
PDS Concurrence: Agree
Target Date: Ongoing / June 30, 2023 Action
Plan:
Staff views this as a parallel process to
recommendation 2 and will update forms and
checklists and improve integration with the
Online Permit System. Staff is also reviewing
the workflow to submit a pre-
application/building permit and anticipates
changes to clarify processes and make the
system more integrated and seamless from
the customer’s perspective.
In Progress Management Update October 2023:
The updated “Apply for a Permit”
website provides customized step-by-
step instructions for each permit type.
Staff has simplified the information on
the Accela Citizen Access (ACA) main
page and created newly released
navigation guides to assist users in
the application process. Staff is
currently developing fillable online
building application forms to integrate
into ACA to provide a more seamless
process.
Because Accela Citizen Access is a
third-party system, staff is limited in
the ability to customize the program.
PDS is exploring other third-party
Accela integrated partners to modify
ACA to be more intuitive for applicants
and understand if other forms can be
embedded within ACA.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
5
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
The OCA recommends to providing better guidance
resources and rejecting any incomplete applications.
PDS Concurrence: Agree
Target Date: June 30, 2023 Action
Plan:
Concurrent with the prior two
recommendations, staff will improve forms,
guidelines and checklists to improve
expectations and establish clear processes to
ensure application submittals are complete
and ready for conversion into a building permit
application.
Complete Management Update October 2023:
The updated “Apply for a Permit”
website provides customized step-by-
step instructions for each permit type,
and staff has created newly released
navigation guides to assist users in
the application process.
PDS also developed simplified
checklists for application submittal.
Previously ranging from 2-15 pages,
requirements have now been reduced
to 1-2 pages and provide clear and
consistent expectations of application
acceptance or rejection, eliminating
the need for pre-application reviews
and routing. If an application is not
accepted, project coordination staff
are also proactively calling applicants
to offer assistance.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
6
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: Requirements for pre-application/application plan review and permitting are not always clear.
The OCA recommends improving notification for all
involved departments of pending reviews
simultaneously at the pre-application stage.
PDS Concurrence: Partially Agree
Target Date: Ongoing / June 30, 2023 Action
Plan:
Sending notification to all involved
departments of pending pre-application
reviews adds significantly more work to
project reviewers supporting the DC. One role
of the coordinator is to vet these issues and
minimize this burden to other plan reviewers.
There currently is no screening process for
pre- applications. Staff is also finding that it is
missing a critical touchpoint with its
customers having made this process
available online. Accordingly, staff is exploring
opportunities to require in- person or virtual
appointments on a pilot program basis to see
if this real-time interaction can improve the
quality of submittals and result the pre-
application to a building permit application at
the meeting instead of relying on an
exchange of email messages and uploading
of application material, which takes a long
time to implement.
Complete Management Update October 2023:
To streamline the application process
and improve communication with
customers, PDS created simplified
checklists for application submittal and
increased internal communications on
plan review deadlines. Previously
ranging from 2-15 pages,
requirements have now been reduced
to 1-2 pages and provide clear and
consistent expectations of application
acceptance or rejection, eliminating
the need for pre-application reviews
and routing.
Once an application is accepted and
routed internally, staff receive
notifications for pending reviews in two
places, the ACA task list by due date
and an email. In August 2022, staff
also developed a pending and late
reviews internal tracking system for
building permits and pre-applications
to provide the Development Center
Permit Manager further visibility into
the application process and enable the
manger to proactively coordinate with
internal partners on their reviews.
During summer 2023, PDS conducted
an appointment pilot program to
understand when an appointment
would be most helpful and impactful to
customers. Staff is working on
optimizing appointments and exploring
requiring appointments for certain
types of applications to help
customers navigate the application
process more effectively and
efficiently.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
7
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: PDF forms required by OPS, including the building permit application, do not always provide sufficient information for review.
The OCA recommends digitizing data collection from
PDF to directly in the OPS system to ensure that all
relevant data is captured.
PDS Concurrence: Agree
Target Date: Ongoing / June 30, 2023 Action
Plan:
Staff is currently having discussions about
using online, fillable forms and integrating this
information into the Accela permitting system.
This effort ties into the other
recommendations to improve access to
forms, checklists and improve processes.
In Progress Management Update October 2023:
Staff is currently working in developing
a building permit application that is
embedded into the ACA. However, not
all forms are able to be embedded
within the platform at this time and a
3rd party vendor is required to develop
this integration. Staff is currently
exploring this option.
PDS is also focusing on streamlining
the application process where
possible through other technologies,
such SolarAPP+ and instant permits.
In collaboration with the National
Renewable Energy Laboratory (NREL)
and the alternative energy industry,
Palo Alto initiated the SolarAPP+ pilot
program in April 2022 to automate
code-compliance review for most
residential roof-top photovoltaic (PV)
projects with select experienced PV
installers. In September 2023, PDS
expanded the SolarAPP+ program to
include both qualifying PV-only and
combination PV and Energy Storage
System (ESS) projects in an effort to
reduce processing times for
applicants. SolarAPP+ is now
available to all contractors with
qualifying projects.
PDS also published a new instant
permit process for Residential Heat
Pump Water Heaters in January 2023
and are currently working to include
Heat Pump Mechanical Residential
Replacements and Residential bath
and Kitchen Remodels (like for like) by
June 2024.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
8
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: PDS does not have a shared and consistent set of Standard Operating Procedures (SOPs).
The OCA recommends development of a robust set
of internal standard operating procedures and
develop timeline and process for routine review and
updates of procedures.
PDS Concurrence: Agree
Target Date: December 31, 2023
Action Plan:
This requires considerable staff resources
and at a time when the department will be re-
examining processes and procedures and
making substantial refinements to forms and
checklists and updates to the department
website. Staff agrees with the
recommendation but will need additional time
fulfil this request.
In Progress Management Update October 2023:
PDS is continuing to make substantial
improvements to refine existing
process and procedures. Once the
Development Center operations are
more static, staff will be establishing a
documented processes and
procedures to ensure internal
standard operating procedure are
documented. PDS will need additional
time to fulfill this request in the next
year.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
9
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: PDS is operating under an outdated initiative for the operation of its building permit function.
The OCA recommends PDS develop an updated
strategic plan reflecting current realities and the
lessons-learned throughout the pandemic.
PDS Concurrence: Agree
Target Date: December 31, 2025
Action Plan:
An updated strategic plan would be helpful to
guide process improvements and would serve
to recommit resources and refine
performance and service expectations.
Significant changes have occurred since the
Blueprint was adopted and it warrants an
update. The staff resources and time needed
to properly prepare an updated strategic plan
is extensive. The department is currently
implementing several structural and
operational changes to respond to a changed
work environment, new challenges, and
adjusting its service model to respond to
challenges. Staff anticipates an updated
strategic plan can begin in about two-years
with completion and report to Council within
three years.
Not Started Management Update October 2023:
PDS is continuing to implement
changes to permitting operations and
service delivery. A strategic plan can
begin in about one year; the
completion of the plan and report to
Council can be expected in about two
years.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
10
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: Technology challenges impede plan review and permitting processes.
The OCA recommends that PDS continues
exploring technology enhancements and better
platforms
PDS Concurrence: Agree Target
Date: Ongoing Action Plan:
This is an ongoing task. The
department’s Data Analysis Team works
daily to make system upgrades and
improvements to respond to internal and
external customer needs. The department
has a request in the FY22-23 budget for an
additional FTE resource to reflect the fact
that the permitting operation requires more
backend support as it shifts to more online
services.
Additionally, the department is currently in
the process of conducting a request for
proposals for an electronic plan review
system; as noted in the audit, the
department currently uses Digiplan, which
was set up on an urgent basis to respond to
the pandemic. Through the RFP process
staff will be able to evaluate available
options.
In Progress Management Update Oct 2023:
In the first half of 2023, PDS completed
a request for proposals for an EDR
software to evaluate for the best
available technology. As noted in the
management action plan, DigEplan was
set up on an urgent basis to respond to
the pandemic and allow for continuity of
services; a contract will be presented to
Council in November 2023
The department is also focusing on
streamlining the application process
where possible through other platforms,
such SolarAPP+ and instant permits.
As noted earlier, PDS expanded the
SolarAPP+ program to include
qualifying PV-only and combination PV
and Energy Storage System (ESS)
projects to reduce processing times for
applicants. SolarAPP+ is now available
to all contractors with qualifying
projects.PDS also published a new
instant permit process for Residential
Heat Pump Water Heaters in January
2023 and are currently working to
include Heat Pump Mechanical
Residential Replacements and
Residential bath and Kitchen Remodels
(like for like) by June 2024.
PDS is also exploring third party
vendors who can improve the existing
user interface of ACA and embed a
wizard to guide applicants through the
process. Implementation of these
changes are anticipated to extend
beyond the timeframe of the audit
update as new technology will need to
be procured, customized and
implemented.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
11
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: Project Coordinator training needs improvement. Inspectors need time for training.
The OCA recommends PDS create materials to train
from and prioritize time for training.
PDS Concurrence: Agree
Target Date: Ongoing/December 2023
Action Plan:
Building inspectors are allotted time for
mandatory training hours.
Project coordinators would benefit from
SOPs as recommended above and this
effort will also track with that timeline.
The project coordinator program has not
fully developed into the proactive project
manager role as envisioned in the Blueprint
and there is department interest in seeing
this through. At the time of this audit,
coordinator staff has experienced significant
disruptions to the manner in which they
provide service to customers, communicate
internally with remote workers supporting
the DC and learn new software systems in
response to the pandemic and shift to online
services. Managers will continue to explore
training opportunities, refine and streamline
processes and prioritize training.
In Progress Management Update October 2023:
Previously impacted by limited staff and
consultant availability, the implemented
structural changes created capacity for
building inspectors and plan reviewers
for training beyond the minimum
requirements to maintain certifications.
All project coordination staff have
attended a training for “How to Properly
Screen Plans for Successful Permit
Services” by the California Building
Officials to improve quality control and
are continuing to enroll in training
opportunities as they arise.
The department is also focused on
expanding training beyond technical
skills and held a mandatory
department-wide two-part training on
customer service, “Staying Courteous
Under Pressure” by Public Sector
Excellence. The first session was held
in October and the next session will
occur early 2024.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
12
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: Palo Alto code modifications increase the complexity of the building plan review and permitting process.
The OCA recommends that interim code interim
modifications are limited as much as possible
PDS Concurrence: Agree Target
Date: Ongoing Action Plan:
Staff agrees that amendments to the building
code should be limited. Staff is also unaware
of any interim building code modifications that
have occurred outside of the State-mandated
cycle. The City does tend to adopt more
aggressive green building standards than the
State mandates but these occur during the
regular adoption cycle.
The planning operation sees many code
updates including interim zoning codes that
may affect development but these are
typically Council-directed policy initiatives or
State-legislative actions.
Complete Management Update October 2023:
Although a new code cycle was
adopted in January 2022, the
department limited changes to state
mandated updates to minimize
impacts to applicants.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
13
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: Quality control processes can be strengthened.
The OCA recommends PDS place a greater
emphasis on quality control and resources to help
promote it.
PDS Concurrence: Agree
Target Date: June 30, 2023 Action
Plan:
Many of the recommendations in this audit
will strengthen quality control. Additional
inspectors, training, SOPs and process
improvements will all help achieve this goal.
Additionally, PDS has put forth a FY22-23
budget proposal for additional staff and
consultant resources to further support
operations and improve processes.
The audit also recommends performance
metrics. Staff will implement these metrics
over the course of the next year and include
them in performance evaluations for PDS
staff and encourage the same for staff
supporting the DC from other departments.
In Progress Management Update October 2023:
Application Processing/Project
Coordinators: PDS added consultant
permit technicians to support application
process and enable staff to learn and
implement updated processes.
Additionally, staff are investing more time
in training to improve their depth of
knowledge and skillsets for consistent
application of technical requirements.
Building Inspection: Transitioning the
building inspection program to fully in
house has addressed inspection wait
times and increased redundancies for
injuries, sick, or other approved leaves.
The building inspection manager is now
able to focus time on staff training and
quality controlling inspections in the field.
Building Plan Review:
Previously, this program was fully
contracted out to various consultant and
due to limited consultant availability, the
manager leading this program was
required to focus time on both quality
control and performing a high volume of
building plan reviews. With the addition of
2.0 staff FTE, the program manager is
able to ensure consistent quality control
across all plan reviewers and is able to
provide training to ensure a standard level
of review.
Although improvements have been made
in the various program areas, additional
work is required to further the emphasis
on quality control and a critical component
of is the development of the standard
operating procedures.
ATTACHMENT A
Status of Audit Recommendations
Building Permit and Review Report – Issued 06/20/2022
14
Recommendation
Responsible
Department(s)
Agree, Partially Agree, or Do Not Agree and
Target Date and Corrective Action Plan
To be completed 6 months after Council acceptance and every 6 months
thereafter until all recommendations are implemented
Current Status Implementation Update and
Expected Completion Date
Finding: Difficulties in hiring and retaining contract staff impede departmental performance.
The OCA recommends that PDS develop plans to
best utilize/balance contract staff.
PDS Concurrence: Agree
Target Date: Ongoing / June 30, 2023
Action Plan:
The department has a strategy for its use of
consultants. Specifically, consultants are
used for plan review services and as
needed to supplement the inspection
program. Onboarding inspection contractors
requires significant training and staff
support and is typically employed when
there is a long-term absence or vacancy.
Staff has been unable to attract any plan
review consultants to report to the
development center since the pandemic.
Accordingly, the department is seeking to
hire an inhouse plan reviewer in the FY22-
23 budget and is exploring possible
changes to consultant contracts to make
Palo Alto more competitive with peer
jurisdictions.
Complete Management Update October 2023:
PDS implemented the following changes
to transition the building inspection
program to a 100% in-house staffing
model and the plan review program into a
hybrid model:
• Added 2.0 FTE Building Inspector
Specialists and 2.0 FTE Plan Check
Engineer in the FY2023 and FY2024
operating budget.
• Collaborated with a consultant to hire
part-time trainee inspectors to invest
into a pipeline for future recruitments
and augment staffing levels to
increase inspection availability at
times of peak volume.
• Created two new classifications,
Senior Building Inspector and Senior
Plan Review Engineer, for market
competitiveness, succession
planning, and retention.
• Reclassed all 8.0 FTE Building
Inspector Specialists to Senior
Building Inspectors and 2.0 FTE Plan
Check Engineer to Senior Plan
Check Engineer to allow the
department to be nimble in
recruitment strategy and flexibility in
responding to attrition.
• Reallocated temporary part-time
administrative support as an HR
liaison to expedite PDS recruitments.
These actions have resulted in the
restoration of inspection availability within
48 hours of a request and the reduction of
late plan reviews.
Policy & Services Committee Agenda Responses
Dear Policy and Services Committee:
On behalf of City Manager Ed Shikada, please find below the staff responses to questions from
Councilmember Tanaka regarding the Tuesday, November 14 Policy & Services Committee agenda
item.
Item 2: STAFF RECOMMENDS THE POLICY AND SERVICES COMMITTEE RECOMMEND THE CITY
COUNCIL ACCEPT THE STATUS UPDATE OF THE AUDIT OF THE BUILDING AND PERMIT REVIEW REPORT
1. The 154 responses received from residents seem disproportionately low considering
the volume of over 3000 permits processed annually. This discrepancy raises the question:
Why were there only 154 response when we have significantly larger resident base
dealing with the Development Center regularly?
Staff response: It was a voluntary survey
2. We would like to understand how the individuals who participated in the survey were
selected. Could you please clarify the criteria and process used for inclusion in the survey?
Staff response: Applicants and customers can participate on through our website or through a link in
staff email signatures. This is a simple self‐selected sampling survey intended capture general feedback
and is open to all who would like to provide anonymous feedback.
3. Can you shed light on the steps taken to mitigate potential biases in the survey,
particularly given the Development Center's reputation among architects, developers,
and others who interact with it?
Staff response: This is not a survey developed by a polling/research firm and may not include all the
statistical measures to account for potential basis. A survey of that nature would be costly and much
more complex. The questions in the survey are not leading and the survey is open to all who would like to
participate. In the next phase of improvement on customer feedback, PDS will be printing cards with a
QR code to hand out to each customer at the end of each inspection appointment to increase
participation in providing feedback.
4. We find these numbers quite intriguing, especially in light of the Development
Center's reputation for being inefficient and difficult to work with amongst many
architects, developers, and residents alike. We kindly request that you share your
insights and any information related to the survey process.
Staff response: The voluntary survey data is helpful as insightful feedback from some patrons to the
Development Center but is not shared to be representative of every visitor. Thus, it is not appropriate to
draw definitive conclusions from the data though it is helpful as an informational input that there are
users with positive experiences as well.