HomeMy WebLinkAboutStaff Report 14373
City of Palo Alto (ID # 14373)
City Council Staff Report
Meeting Date: 6/20/2022 Report Type: Consent Calendar
City of Palo Alto Page 1
Title: Policy and Services, Office of the City Auditor and Staff recommends
that City Council Approve the Building and Permit Review Report
From: City Manager
Lead Department: City Auditor
Recommended Motion
Policy & Services Committee, City Auditor and Staff recommends that City Council
consider the following action:
1) Review the Building Permit Process Review report and corresponding
recommendations for improvement and consent.
Executive Summary
Baker Tilly, in its capacity serving as the Office of the City Auditor, performed an
assessment of the City's Building & Permit Process. This assessment was conducted in
accordance with the FY2021 Audit Plan approved by City Council.
Through the audit activity, the Office of the City Auditor identified fifteen (15)
recommendations and opportunities for improvement. Planning & Development Services
concurred with each finding and has drafted action plans for each item.
The Office of City Auditor will perform periodic follow up procedures to validate that
corrective actions have been implemented.
Background
Planning & Development Services (PDS) is responsible for long range planning, current
planning, code enforcement, building permits, and building inspections. The chief
planning official oversees long range and current planning and code enforcement, with
the chief building official overseeing building inspections, plan check, and development
services – which leads issuance of building permits. Both officials report to the PDS
assistant director. The PDS director has direct reports that include the assistant director
and departmental support functions.
City of Palo Alto Page 2
The current iteration of PDS was created from the merger of the Planning and
Community Environment Department and Development Services Department during
fiscal year 2020. The merger was designed to “create one cohesive unit focused on
entitlements, permitting, code enforcement, and land use visioning” – per the City’s
2020 budget document. This area has been the subject of additional reorganizations
over the last decade as well.
This audit focuses in particular on the building permit and inspection processes. Building
permits are issued through the City’s Development Center, which was created
approximately a decade ago to help centralize and better coordinate the permitting
process across all City departments and provide a more ‘one stop shop’ model for
residents, contractors and the like. PDS issues a number of different building permits –
including for ‘minor’ smaller scale projects (direct permits) and larger projects for
residential and commercial projects that require more in-depth review.
Discussion
The attached report summarizes the analysis, audit findings, and recommendations.
Timeline, Resource Impact, Policy Implications
The timeline for implementation of corrective action plans is identified within the
attached report. All corrective actions are scheduled to be implemented by FY 2023.
Stakeholder Engagement
The Office of the City Auditor worked primarily with Planning & Development Services
and engaged with additional stakeholders, including the City Manager’s Office and City
Attorney’s Office, as necessary. In addition, the scope of services included engaging
building permit applicants, as outlined in the report.
The Office of the City Auditor included an audit activity related to the adjustment in the
FY2021 Audit Plan approved by City Council. The objectives of the Building Permitting
Process Review are to:
(1) Identify the highest impact areas to focus the assessment (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
City of Palo Alto Page 3
Environmental Review
Environmental review is not applicable to this audit activity.
Attachments:
• OCA - Building Permit Process Review (Final Draft)
1
City of Palo Alto
Office of the City Auditor
Building Permitting Process
Review
April 10, 2022
2
Executive Summary
Purpose of the Audit
Baker Tilly, in its capacity serving as the Office of the City Auditor, performed a review of the building permitting process in
accordance with the FY2021 Audit Plan approved by City Council. The objectives of this review were to:
1) Identify the highest impact areas to focus the assessment (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
Report Highlights
Key Findings Page # Description of Finding
The lead time for a
building inspection is
approximately two weeks
from request to
inspection.
35 Lead times have been as long as 2 weeks between the time a building inspection
is requested to an inspector arriving on-site. While this has improved at times
during the OCA’s review, the lead times remain a consistent concern within
Planning & Development Services (PDS) and for its customers. In addition, any
improvements are precarious with a staff absence – whether planned or due to
injury, etc. that can quickly erode any improvement to lead time. In addition,
contract inspection staff, who could be utilized to help with lead times, have been
difficult to obtain, particularly after the start of the pandemic. Long lead times
result in a host of compounding issues, with contractors scheduling inspections
far in advance of work being completed – resulting in either inspectors arriving
before work is complete or re-scheduling of appointments. This is confirmed by
the examination of inspections requested – with 18% of inspections requested
being cancelled.
Customers/applicants
need better information
on all aspects of the
permitting and inspection
process.
37 This finding closely relates to a number of the other observations within this
report related to enhancing the customer service experience. Overall, the
building permitting process would benefit from improved availability of
documentation for all aspects of the permitting process, including checklists,
forms and guidelines. These resources can be difficult to locate and also need
updating (particularly related to the ability to submit applications on-line). In
addition, customers would benefit from continued enhancements to the on-line
permitting system – particularly those related to streamlining the process.
Further, the customer experience would benefit from additional training of staff
and communication across departments.
PDS is operating under
an outdated initiative for
the operation of its
building permit function.
45 PDS is operating under a decade plus old strategic plan - ‘Blueprint for a New
Development Center’ – which created the Development Center. While the
model has helped to improve cooperation between departments and provide a
one-stop-shop for applicants, this blueprint was developed prior to any permits
or intake of information being done virtually. A full-fledged strategic planning
process should be conducted in the near future. The OCA acknowledges a
strategic planning process is a significant and lengthy undertaking; however,
the City needs to be cognizant of what the building permitting process will look
like in post-pandemic times to ensure alignment with process improvements,
staffing, and related items.
3
Key Recommendations to the City Manager:
• Work towards improving inspection lead times by hiring an additional
building inspector and implementing other efficiency measures
• Continue efforts to enhance and improve the on-line permitting system,
including availability and accuracy of guidance documents and
enhancing the user interface.
• Keep future vision for the building permitting process in mind with return
to more normal operations post-pandemic, particularly related to
balance of in-person versus on-line permitting and how this impacts
staffing, resources, etc.
4
Table of Contents
Executive Summary ........................................................................................................................................................... 2
Purpose of the Audit ..................................................................................................................................................... 2
Report Highlights ........................................................................................................................................................... 2
Objective ........................................................................................................................................................................... 5
Background ..................................................................................................................................................................... 5
Scope ................................................................................................................................................................................. 5
Methodology .................................................................................................................................................................... 5
Compliance Statement .................................................................................................................................................. 6
Organizational Strengths ............................................................................................................................................. 7
Overview ........................................................................................................................................................................... 8
Building Permit Data Analysis .................................................................................................................................... 9
Interviews with Staff .................................................................................................................................................... 14
Organizational Analysis ............................................................................................................................................. 21
Customer Survey ......................................................................................................................................................... 23
Building/Contractors Associations Feedback ..................................................................................................... 28
Audit Results ..................................................................................................................................................................... 33
Appendices ........................................................................................................................................................................ 53
Appendix A: Customer Survey ................................................................................................................................. 53
Appendix B: Management Response ..................................................................................................................... 67
5
Introduction
1 https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/reports/city-manager-reports-cmrs/2021/id-11952-
[80076].pdf
Objective The objectives of the Building Permitting Process Review are to:
(1) Identify the highest impact areas to focus the assessment (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
Background During the FY2021 risk assessment1, the Office of the City Auditor (“OCA”) noted risk areas
regarding the building permitting process. For context, permits are mandated before all
construction and/or remodeling projects, with the option to file in-person at City Hall (prior to
the COVID-19 restrictions) or through the Online Permit Services System.
The planning function will provide building permits based on the function's broader
Comprehensive Plan 2030, compliance with the California Environmental Quality Act
(CEQA), Plan Review (a fully outsourced service) and other codes and regulations. There is
also an Architecture Review Board that consults on the decision for new proposals. All of
these factors are considered when making decisions regarding proposals and requests.
This may come with some potential risks, including:
• Individuals/businesses may not apply for permits or request inspections before
initiating projects or the potential for delays or backlogs in providing permitting and
inspection services
• Potential disagreement around the interpretation of current codes and regulations,
increasing the amount of discretion necessary in decision making
• Pressure on existing staff and lower overall quality with high quantities of new
building proposals required for review
While these are only examples, the risk assessment identifies risks in the permitting process
as higher likelihood than average. Permitting is an important function in City operations,
worthy of an internal audit to ensure efficient operations and mitigated risk.
Scope The scope includes process review for key permit types in order to identify opportunities for
improvement and risk mitigation.
Methodology The audit activity was conducted in four steps. The following is a description of each step of
our methodology.
Step 1 – Audit Planning
This step consisted of the tasks performed to adequately plan the work necessary to
address the overall audit objective and to solidify mutual understanding of the audit scope,
objectives, review process, and timing between stakeholders and auditors. Tasks include:
• Gathered information to understand the environment under review
• Secured agreement on the audit objectives
• Assessed the audit risk
6
• Wrote an audit planning memo and audit program
• Announced the initiation of the audit and conduct a kick-off meeting with key
participants
Step 2 – Organizational and Business Process Analysis
This step involved executing the procedures in the audit program to gather information,
interview individual process owners and participants, survey appropriate industry
stakeholders, conduct focus groups and field observations, and analyze the data and
information gathered in order to obtain sufficient evidence to address the agreed-upon audit
objectives.
Audit procedures included, but were not limited to:
• Interviewed the appropriate internal and external stakeholders and process
owners
• Narrowed focus to high risk permitting categories/types as determined through
the planning process
• Administered a confidential survey of inspections process stakeholders
• Reviewed the building codes, state statutes, and other applicable governance
documents
• Performed test procedures and reviewed of selected supporting documents
• Benchmarked operational performance against industry best practices
Step 3 – Reporting
In Step 3, the project team will perform tasks necessary to finalize audit working papers,
prepare and review a draft report with the stakeholders, and submit a final audit report.
Tasks include:
• Developed findings, conclusions, and recommendations based on the
supporting evidence gathered
• Validated findings with the appropriate individuals and discussed the root cause
of the identified findings
• Completed supervisory review of working papers and a draft audit report
• Distributed a draft audit report and conducted a closing meeting with key
stakeholders
• Obtained written management responses and finalized a report
• Reviewed report with members of City Council and/or the appropriate Council
Committee
• Presented the final report to the City Council and/or appropriate Council
Committee
Compliance
Statement
This audit activity was conducted from July 2021 to December 2021 in accordance with
generally accepted government auditing standards, except for the requirement of an
7
[1] Government auditing standards require an external peer review at least once every three (3) years. The last peer review of the
Palo Alto Office of the City Auditor was conducted in 2017. The Palo Alto City Council approved a contract from October 2020
through June 2022 with Baker Tilly US, LLP (Baker Tilly) and appointed Kyle O’Rourke, Principal in Baker Tilly's Public Sector practice,
as City Auditor. Given the transition in the City Audit office, a peer review was not conducted in 2020 and will be conducted in the
second year of Baker Tilly’s contract.
external peer review[1]. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives.
Organizational
Strengths
During this audit activity, we observed certain strengths of the City. Key strengths include:
- Quick adaptation to a remote working environment
- Prompt to make improvements when opportunities are discovered
- High level of expectations and work ethic among Planning & Development Services
(PDS) staff
Additionally, the OCA commends the City for its response to COVID-19. In particular, we
greatly admire all efforts taken to support the health and well-being of Palo Alto citizens as
well as the support of essential workers during this time of heightened risk.
The Office of the City Auditor greatly appreciates the support of the Planning &
Development Services Department in conducting this audit activity.
Thank you!
8
Detailed Analysis
Overview
Planning & Development Services (PDS) is responsible for long range planning, current planning, code enforcement,
building permits, and building inspections. The chief planning official oversees long range and current planning and code
enforcement, with the chief building official overseeing building inspections, plan check, and development services –
which leads issuance of building permits. Both of these officials report to the PDS assistant director. The PDS director has
director reports that include the assistant director and departmental support functions.
The current iteration of PDS was created from the merger of the Planning and Community Environment Department and
Development Services Department during fiscal year 2020. The merger was designed to “create one cohesive unit
focused on entitlements, permitting, code enforcement, and land use visioning” – per the City’s 2020 budget document.
This area has been the subject of additional reorganizations over the last decade as well.
This audit focuses in particular on the building permit and inspection processes. Building permits are issued through the
City’s Development Center, which was created approximately a decade ago to help centralize and better coordinate the
permitting process across all City departments and provide a more ‘one stop shop’ model for residents, contractors and
the like. PDS issues a number of different building permits – including for ‘minor’ smaller scale projects (direct permits)
and larger projects for residential and commercial projects that require more in depth review.
As part of this audit activity, the OCA conducted a number of different analysis approaches to help develop a well-rounded
perspective of the City’s building permit and inspection processes. The following section of the report provides an
overview of each approach and a summary of significant findings.
• Building Permit Data Analysis – includes an overview of volume of building permits over last several years and
more in depth examination of number of permits for photovoltaic projects.
• Interview with Staff – includes list of interviewees from PDS and City, general questions asked, and summary of
themes from interviews.
• Business Process Review – detailed analysis of the building permits process, including process flow charts.
• Organizational Analysis – includes an overview of departmental structure, staffing, and technology utilized.
• Customer Survey – contains list of survey questions sent to all recent applicants for a building permit and a
summary of themes from responses.
• Building Industry Associations Feedback – details trade associations contacted to gain additional perspectives on
the City’s building permit and inspection processes.
• Code Review and Benchmarking – includes comparison of City’s permit process with comparable cities and more
detailed examination of their photovoltaic code.
9
Building Permit Data Analysis
The OCA examined data provided by PDS in a number of key areas, including building permit type and volume and also
number of inspections requested and current status. The following offers summary tables and brief narrative to explain
insights gained. This analysis helped to inform and guide our further observations and recommendations included within
this report.
Overall, analysis of the provided data insights into overall volume of the permits and variability between types and how
this has been impacted by the pandemic. In addition, our analysis examined how many of permits applied for involve
some type of photovoltaic component – a key area of concern the City and City Council. In addition, we looked further into
the number of inspections performed with more in depth analysis on inspections requested that were either cancelled by
the resident/contractor or deemed not ready for inspection.
Building Permit Data
The OCA examined the number of permits submitted over the last several years to gauge what types of permits had the
highest volume and examine other trends.
Total permits submitted has been impacted in recent years from a level of approximately 4,000 permits submitted annually
in 2018 and 2019 – with 2020 showing just under 3,000 total permits submitted. Permits submitted has rebounded in 2021
with over 3,700 permits submitted. Demand for permits decreased in 2020 – driven largely by construction slow down due
to the pandemic.
10
Demand for residential permits of all types far exceeded commercial permits with residential permits in the three major
areas shown totaling nearly half (nearly 1,800) of all permits submitted for 2021. Commercial permits submitted totaled
between 500 to 600 annually for 2018 and 2019 – but have dropped considerably with 330 submitted in 2020 and near
350 submitted for 2021.
The OCA summarized the 36 different categories of permits that PDS tracks to analyze and better display overall trends.
The following is list of these categories to align with the above graphic:
OCA Summarized Grouping Category Description Category/Construction
Type Code
Resisdential - New Residential - New Single Family 101
Residential - New Two Unit Bldg 103
Residential - New 3 -4 Unit Bldg 104
Residential - New 5 units or more Bldg 105
Residential - New Mixed Use (Commercial/Residential) Bldg 107
Commercial - New Commercial - New bldg 328
Res - Elec/Mech/Plum Only Residential - Electrical/Mechanical/Plumbing only 432
Res - Remodel/Rep/Add Residential - Remodel/Repair 433
Residential - Addition and Remodel 434
Comm - Elec/Mech/Plum Only Commercial - Electrical/Mechanical/Plumbing only 435
Comm - Remodel/Rep/Add Commercial - Remodel/Repair 436
Commercial - Addition and Remodel 437
Deconst/Demo Residential - Deconstruction 644
Residential - Demolition 645
Residential - Deconstruction Garage/Carport/Accessory Bldg 646
Residential - Demolition Garage/Carport/Accessory Bldg 647
Commercial - Deconstruction 648
Commercial - Demolition 649
Commercial - Interior Non-Structural Demolition 650
Re-Roofing Re-Roofing 331
Revision Revision - Revision to Issued Building Permit 910
Direct Permit Repair Gas Leak - Direct 'Online' Permit 991
Boiler Replacement - Direct 'Online' Permit 992
Furnace Replacement - Direct 'Online' Permit 993
Re-Roofing - Direct 'Online' Permit 994
Water Heater Replacement - Direct 'Online' Permit 995
Backflow Device - Direct 'Online' Permit 996
Window Replacement - Direct 'Online' Permit 997
Re-Pipe Water Piping System - Direct 'Online' Permit 998
Other Non Bldg Structures (sign, bus shelter, etc)329
Pool/Spa 330
Landscape 333
Use and Occupancy Only 431
Residential - Garage/Carport/Accessory Bldg 438
Building Moving/Relocation 651
Miscellaneous (Noise Exemption, Parking Pass, etc) 900
11
The OCA further analyzed the building permit data to examine the number of permits that were for photovoltaic (PV),
solar, and heat pump projects. With the City’s Sustainability & Climate Action Plan, these projects are of particular
importance to the City and its residents. As such, the OCA examined the permit submitted data to pull out this information
as PV, solar, and heat pump projects can be included in a number of the categories shown above. The OCA analyzed the
description from all permits issued by PDS over the last four years to aggregate the following. Up until early 2021, PDS
did not have a separate flag or way of tracking photovoltaic permits issued.
In aggregating the data, the OCA made every effort possible to not double count between the categories indicated within
the table. Overall volume for these types of projects continue to increase, even with pandemic related pressures that likely
caused decrease in overall permit volume as discussed earlier in report. While permits related to these projects have
been between 200 to near 350 permits annually – this is still less than 10% of the overall number of permits issued by
PDS on an annual basis.
Inspection Data
PDS provided the OCA with the current inspection status for all inspections requested for from 2018 to 2021. The
following chart shows the total number of inspections requested and performed by PDS inspectors (not other
departments, i.e. Fire, Public Works, etc.). Of note, this table includes all inspections requested, regardless of ultimate
status including approved, cancelled, not approved, etc.
12
As with permits submitted, inspections requested has also decreased since 2018, again driven by pandemic related
pressures. Number of inspections for 2021 has increased slightly at just over 22,400 – but still below the 2018 level of
nearly 30,000, a near 25% decrease.
The OCA further examined inspections for PDS inspectors that were requested, but were then either cancelled prior to the
inspection date scheduled or deemed to be not ready for inspection once the inspector arrived.
The number of inspections requested and then cancelled totals just over 4,000 for 2021, with a approximately 800
additional scheduled inspections deemed not ready. For 2021 this totals nearly 5,000 scheduled inspections – nearly 22%
of total inspections requested - that were scheduled, but did not result in an inspection being completed. Cancelled and
not ready inspections for 2021 is down as compared to 2020 – where over 25% of inspections were cancelled or deemed
not ready. However, 2021 is still higher on a percent basis than the 2018 level of approximately 19%. Notably, just over
5,500 inspections were cancelled or deemed not ready in 2018 as compared to approximately 4,900 in 2021, even though
the number of total inspections requested in 2021 was approximately 25% less.
Themes
0
5
10
15
20
25
30
35
2018 2019 2020 2021
Th
o
u
s
a
n
d
s
Inspections Requested by Year
13
Observations from OCA’s analysis of building permit data and related information include:
• Overall permit volume decreased significantly in 2020 due to pandemic related pressures.
• Permit volume is recovering in 2021
• PV and solar projects account for less than 10% of overall permits issued by PDS.
• Inspections requested has seen a 25% drop from 2018 to 2021.
• Inspections requested and then either cancelled or deemed not ready for inspection account for over 20% of total
inspections requested in 2021.
14
Interviews with Staff
The OCA conducted a review of the building permitting and inspection processes through a number of interviews with key
stakeholders and process owners. Staff interviews provide valuable insights into the overall process and provide the OCA
with background on the inner workings of the processes. In addition, staff often provide suggestions for improvement that
will benefit the overall process and ultimately the applicants and the City. The following includes general questions asked,
list of those interviewed by title/function and a summary of overall themes from the interviews.
Throughout these interviews, the OCA collected observations based on themes and patterns heard in interviews. These
interviews were key in terms of informing our understanding of the process and also formulating a prioritized list of key
areas of concern and corresponding recommendations for improvement (as outlined later in this report).
The interviews were conducted in a conversational format to provide the interviewees with the opportunity to openly share
about the process, their role in the process, and any other points of interest or concern. For consistency, we generally
asked questions similar to the following:
• Where do you feel like the permitting process is the smoothest? What permitting types are the department’s bread
and butter?
• What permitting types tend to cause the most customer complaints?
• What permitting types tend to cause the greatest drain on internal resources?
• What permitting types tend to be prone to error in the process?
• Where do you face the most bottlenecks in communications?
• Are there positions currently in which only one person has a key piece of knowledge? What do you do when that
person is out of the office?
• How is workload distributed among your team and the department as a whole? Are there any teams who are
bottlenecks due to having regularly heavy workload?
• What areas in the permitting operations feel like there may be missing reviews/approvals? Any areas in which
quality assurance is an issue?
• Where might there be a lack of documentation or standardized process?
• What systems are you using most often in your day to day? Do they meet your needs?
• Where are their heavily manual steps in the process? Are these steps necessary to be manual?
The OCA interviewed PDS staff and other City department staff. The other City department staff interviewed include those
that help staff the Development Center and/or are heavily involved in the permitting and inspection processes. In some
cases – particularly with manager or above level staff in PDS, we conducted follow up interviews for clarification and
further information to best inform our review.
The following is a list of staff interviewed as part of our work (the number in parentheses following a title indicates how
many staff within that title we interviewed):
• Director, Planning and Development Services
• Assistant Director, Planning and Development Services
• Chief Building Official
• Assistant Chief Building Official
• Current Planning Manager
• Inspection Manager
• Development Services Manager
• Building Inspector Specialist (3)
• Project Coordinator (5)
• Senior Management Analyst
• Senior Business Analyst
In addition to PDS staff, we also interviewed a number of City staff who support the building permit and inspection
processes. The following is a list of staff by title interviewed as part of our work:
• Public Works Manager – Engineering
• Acting Deputy Chief – Fire Marshal (2)
15
• Acting Urban Forestry Manager
• Utilities Manager
• Public Works Manager – Water
• Senior Industrial Waste Investigator
• Public Works Manager – Zero Waste
• Zero Waste Coordinator
• Public Works Manager – Deconstruction
Themes
Observations from OCA’s interviews with staff include:
• Drive to continue to improve and refine OPS to improve overall process.
• Desire to improve overall cycle times (i.e. time from initiating permit/inspection to completion) for all processes.
• Need to provide better resources and information on-line to applicants/customers.
• Need to create better internal documentation for processes to ensure consistency.
• Improve communication between PDS staff and departments supporting Development Center.
16
Business Process Review
Detailed Permitting Process Walk Through
The OCA conducted a detailed analysis of the building permitting process with walkthrough interviews. Throughout these interviews, the OCA sought to
understand the process steps, the individual(s) completing each step, nuances of the process step requiring a special process note, and risks associated with any
given process step (or with a process as a whole). After conducting these interviews, the Team documented each major process step in a process flow to clearly
notate additional comments on the process and associated risks.
These risks are areas in which the City can improve its overall process. Not all of these risks are immediate needs, but these represent pain points in the customer
experience or inefficiencies in internal operations. Without planning to address these risks, the City may not be operating at its full capacity, nor serving its
customers to the fullest potential.
A summary of specific process risks are as follows:
Process Phase Risk Notes
Pre-
Application
Even if the pre-application process is completed fully and accurately, the applicant is still required to answer additional information, complete
fee payments, and submit additional uploads. However, most often the pre-application materials are lacking, meaning that there is still the
“application phase” for the applicant after having submitted this information. The title of “pre-application” terminology does not properly set
applicant expectations, setting applicants up for frustration. Applicants have noted confusion over various application types if not familiar with the system. Furthermore, there are no descriptions or links to
descriptions in the OPS system, so applicants would have to search separately for descriptions on Palo Alto’s website.
The OPS system requests detailed description for the pre-application, but there is no guidance as to how long this description should be or
what should/should not be included. Consequentially, applicants aren’t sure if they are missing information. Applicants are required to submit supporting documentation in the pre-application process, but the OPS system does not provide guidance
regarding what documentation is needed, nor does it provide a link to find the information on the website. The documentation is also required
to be in PDF format with a specific naming convention, but this is not detailed in the OPS system either. Applicants would have had to watch
the video or read the instructions on the separate Palo Alto building permits website to have known about this. The Palo Alto team regularly
receives incorrect document submissions because of these issues.
Pre-
Application
Review
The cloning process is the method by which the project coordinator copies and pastes information from the pre-application to the application.
This requires manual entry. If all information in the pre-application is proper, the cloning process is quick. But oftentimes pre-applications come
in with improper naming conventions. As stated in the pre-application phase, there is not guidance for the applicant in the online permitting
system in regards to naming conventions. When pre-application acceptance auto generated emails are sent to applicants, oftentimes applicants consider this to be an acceptance of their
application. This causes confusion for applicants who aren’t familiar with the process. Applicants should wait for all departments to complete their review prior to receiving the necessary changes due to the limitations on OPS, but
applicants will tend to make changes prematurely prior to receiving all comments from all departments.
17
Process Phase Risk Notes
Application
Review and
Issuance
It is common when an application is resubmitted to have new errors that didn’t exist in previous versions. This is particularly relevant in naming
conventions. If naming conventions are slightly off, the project coordinator may manually make changes, but otherwise the project coordinator
will push the application back to the applicant. It is uncommon for applications to move to the issuance process on the first round. Most applications require some revisions.
18
Palo Alto Building Permitting Process
Ap
p
l
i
c
a
n
t
Pre-Application Submission
Begins permitting
process
Calls, comes in-
person, or visits
website to begin
application
Submits Pre-
application
1
Registers for an
account with OPS
Logs in and begins
pre-application
3
Creates project
location
Creates project
details
Creates project
contact
If applicable,
includes project
contractor
Attaches supporting
project
documentation per
guidelines on
website
Reviews pre-
application and edits
if necessary
32 4
1
2
A
Process Notes
1. Palo Alto provides videos and to-do lists on the website for applicants on the webpage. Additionally, there are multiple places to click to apply for a building permit, including the home
page of Palo Alto’s webpage. If applicants were to arrive in-person, the process would remain the same, only with the applicant being guided by a Palo Alto employee.
2. Palo Alto employee audits the minor permit types to see if any applicants improperly use that permitting type to complete work with a broader scope.
3. For minor permitting types, applicants can receive a same-day permit without the need for Palo Alto staff touchpoints. This still goes through the OPS system, but doesn’t require the same
level of review.
Risk Notes
1. Even if the pre-application process is completed to perfection, the applicant is still required to answer additional information, complete fee payments, and submit additional uploads.
However, most often the pre-application materials are lacking, meaning that there is still the “application phase” for the applicant after having submitted this information. The title of “pre-
application” terminology does not properly set applicant expectations, setting applicants up for frustration.
2. Applicants have noted confusion over various application types if not familiar with the system. Furthermore, there are no descriptions or links to descriptions in the OPS system, so
applicants would have to search separately for descriptions on Palo Alto’s website.
3. The OPS system requests detailed description for the pre-application, but there is no guidance as to how long this description should be or what should/should not be included.
Consequentially, the Palo Alto team receives a wide variety of responses and applicants aren’t sure if they are missing information.
4. Applicants are required to submit supporting documentation in the pre-application process, but the OPS system does not provide guidance regarding what documentation is needed, nor
does it provide a link to find the information on the website. The documentation is also required to be in PDF format with a specific naming convention, but this is not detailed in the OPS
system either. Applicants would have had to watch the video or read the instructions on the separate Palo Alto building permits website to have known about this. The Palo Alto team
regularly receives incorrect document submissions because of these issues.
19
Palo Alto Building Permitting Process
Pr
o
j
e
c
t
C
o
o
r
d
i
n
a
t
o
r
Re
l
e
v
a
n
t
De
p
a
r
t
m
e
n
t
s
Pre-Application Review
A
Sends to all other
departments for
pre-check of pre-
application
Clarifies necessary
edits or additions to
pre-application to
applicant
Clones Pre-
Application to
formal application
with relevant
information
1 1
Pre-application
complete and
accurate?
Review pre-
application for
accuracy
Reviews pre-
application for
completeness and
accuracy
Pre-application
accurate?
Yes
No
Yes
No
Invoices Review
Fees, sending auto
generated email
Accepts pre-
application and auto
generates email
2
B
2
A
Process Notes
1. Project Coordinator sends to other departments at their discretion. The Project Coordinator may not feel it is necessary to send to other departments for a pre-check.
2. Depending on the plans submitted, some departments will require a review of the pre-application while others will not. This is determined by the project coordinator.
Risk Notes
1. The cloning process is the method by which the project coordinator copies and pastes information from the pre-application to the application. This requires manual entry. If all information
in the pre-application is proper, the cloning process is quick. But oftentimes pre-applications come in with improper naming conventions. As stated in the pre-application phase, there is not
guidance for the applicant in the online permitting system in regards to naming conventions.
2. When pre-application acceptance auto generated emails are sent to applicants, oftentimes applicants consider this to be an acceptance of their application. This causes confusion for
applicants who aren’t familiar with the process.
20
Palo Alto Building Permitting Process
Pr
o
j
e
c
t
Co
o
r
d
i
n
a
t
o
r
Re
l
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v
a
n
t
De
p
a
r
t
m
e
n
t
s
Ap
p
l
i
c
a
n
t
Application Review and Issuance
Pays invoice for
review fees
Routes applicable
sections of
application to send
to the appropriate
departments
1
Reviews application
for accuracy
Creates comments
with missing
information
Application
accurate?
Collects and
compiles comments
for all necessary
revisions
Auto generated
email is sent to
applicant with
compiled list of
necessary edits
Makes necessary
edits and resubmits
new packet
No
1
2
Sends invoice with
additional fees other
than review fees
3 2
Yes
Pays fee online
Sets status to
issuance and sends
automated email
End
3
B
4
Process Notes
1. Application is only set up after applicant has paid review fees
2. All fees associated with the permitting process other than the already paid review fees are included, including inspection fees, record retention fees, etc.
3. Includes all stamped and approved documents
4. Applicant may print the issued permit if desired
Risk Notes
1. Applicants should wait for all departments to complete their review prior to receiving the necessary changes due to the limitations on OPS, but applicants will tend to make changes
prematurely prior to receiving all comments from all departments.
2. It is common when an application is resubmitted to have new errors that didn’t exist in previous versions. This is particularly relevant in naming conventions. If naming conventions are
slightly off, the project coordinator may manually make changes, but otherwise the project coordinator will push the application back to the applicant.
3. It is uncommon for applications to move to the issuance process on the first round. Most applications require some revisions.
21
Organizational Analysis
The OCA examined the organizational structure and technology utilized by PDS to better understand how the department operates and identify key players in the
process. History of staff serving in key roles are taken from the staff interviews and help to provide an understanding of department turnover and expertise of staff
currently filling roles. The technology utilized to support the process was a further point of examination to develop an understanding of how well technology
solutions that are currently in place are supporting the process.
The permitting and inspection processes for the City primarily reside under the Chief Building Official (CBO) who reports to the Assistant Director of Planning and
Development Services. PDS provided the organizational chart for fiscal year 2022 – the below captures the CBO’s direct reports:
Positions reporting to the CBO are all recent hires, but with prior experience in the City, as follows:
22
• Inspection Manager was hired into the role after serving 6 years as a contact inspector with the City. Has been in this role as inspection manager for the
last 2 years, with a number of years of experience prior to working for the City.
• Development Services Manager was previously a planning manager until position was eliminated due to department restructuring, given opportunity to
apply for current role. Has been in the development services manager role now for 1 ½ years – over 20 years experience with City overall nearly all in
planning.
• Assistant CBO started in June 2021 and previously served for a number of years as the contracted lead plan reviewer for the City. Assistant CBO is a
licensed engineer and has a number of years experience in the industry, including serving as a building official.
Items of note on the staff reporting to the CBO’s direct reports include:
• Inspection staff was significantly reduced at start of pandemic with temporary slowdown in constructions projects. As a result of slowdown, contract
inspectors were let go – reducing the field inspection staff by approximately half. Recently onboarding an additional inspector – which will bring number of
inspectors in field up to six total.
• Plan check staff are all contracted staff.
In terms of technical operations, PDS primarily utilizes the Accela system to support its technology needs. The Accela Civic Permitting System for tracking and
monitoring permit applications and inspections and to manage the associated workflow. Accela Citizen Access is also used by PDS to drive its Online Permitting
Service (OPS) for residents/contractors to apply for building permits and associated tasks and to pay fees on-line.
OPS was brought on-line after the COVID-19 pandemic required remote work and less in-person interaction. Prior to the implementation of OPS, PDS accepted
on-line application for minor building permits that were issued instantly – such as boiler/furnace/water heater replacement, backflow device, re-piping water
system, re-roof, repair gas leak, and window retrofit. All other permits were initiated and ultimately issued by the applicant going to the Development Center and
meeting with a project coordinator.
As part of the switch to acceptance of permit applications on-line, PDS needed a way to review plans submitted by applicants as part of the building permit
application process. PDS’s Accela technology consultant recommended DigEplan as the consultant knew the product well and that it would integrate with Accela.
Beginning this summer, as more in-person interactions became possible, PDS created appointments for applicants to schedule an in-person meeting with a project
coordinator to assist with permit applications and related questions. These appointments are available 4 days a weeks, Monday through Thursday, with 4
appointment slots available on each day. PDS also has virtual appointment slots available five days a week as well to assist applicants. Scheduling for both in-
person and virtual appointments can be done on the PDS website.
In addition, PDS utilizes the iRequest app from CityGovApps, which was implemented and customized to meet the City’s needs and replaced a prior app that had
poor functionality, per PDS staff.
Themes
Observations from OCA’s organizational analysis include:
• Management under the CBO has seen a fair amount of turnover over the last several years.
• A number of recent PDS hires are from within the department or contract staff supporting PDS.
• Ability to quickly implement an on-line process for submitting permits that were previously done in-person/paper based.
23
Customer Survey
As part of our review, the OCA sent a survey to past applicants for a building permit in the City. The OCA initiated the survey to gain a first hand account from
building permit applicants on their experiences with the permit and inspection processes and better understand what is working (and not). The survey asked a
range of questions regarding the applicant’s role, frequency of applying, satisfaction with the permit and inspection processes, and other aspects of the process. Of
the near 1,200 past applicants emailed, we received approximately 250 responses. The following offers highlights and general themes of their responses. The
complete list of survey questions and summarized responses to each question are provided in Appendix A.
The following is a list of questions included in the survey:
1. What best describes your role in the permitting process?
2. What type of permit(s) did you apply for (check all that apply)?
3. When did you last apply for a permit?
4. How often do you apply for building permits?
5. Were you aware the City of Palo Alto Development Center is offering in-person appointments for assistance in submitting a building permit application?
Yes or No
6. Did you use the in-person service or the on-line application process?
7. Please rank the following from highest to lowest as to where you would like to the City focus its time and resources in improving the permitting process: A.
Online permitting process; B. In-person permitting process; C. Appointment availability for in-person permitting; D. Availability of staff for questions; E.
Clarity of requirements; F. On-line resources/reference documents; G. Turnaround time from application to permit (cycle time); H, Expedited permit for
additional fee
8. Please provide any other additional comments/suggestions on the above ranking.
9. What is your perception of the following areas of additional steps and requirements related to the permit application and review process? A. Tree
preservation and protection; B. De-watering requirements; C. Architectural review; D. Deconstruction and demolition; E. Utilities coordination
10. Provide additional comments on your above responses
11. Please rate your overall satisfaction with the permitting process
12. What suggestions for improvement of the permitting process do you have?
13. Please rank the following from highest to lowest as to where you would like to the City focus its time and resources in improving the inspection process: A.
Wait time between request for inspection and actual inspection; B. On-site inspection visit; C. Clarity of inspector’s report/findings; D. Training/knowledge
of inspectors; E. Reinspection wait time; F. Overall satisfaction with the inspection process
14. If you apply for permits in other jurisdictions, how does Palo Alto’s process compare?
15. If you have any other additional thoughts – please feel free to share.
In terms of overall satisfaction with the permitting process, responses were fairly evenly distributed between satisfied and dissatisfied. Respondents feeling slightly
more positive about the permitting process narrowly outpaced those feeling slightly negative about the process – with a large number of respondents feeling
neutral overall.
24
In addition, we asked respondents how the City’s permitting process compared to other jurisdictions where they may apply for permits. Overall, the respondents
viewed the City’s permitting process as worse than average; however nearly half of respondents viewed the City’s process as comparable to better than average.
Extremely Dissatisfied, 19%
Somewhat Dissatisfied, 24%
Neither Satisfied nor Dissatisfied, 20%
Somewhat Satisfied,
25%
Extremely Satisfied, 12%
Overall Satisfaction with Permitting Process
25
The OCA also asked if respondents were aware of the in-person appointments being offered at the Development Center to answer questions on building permit
questions. Well over half of respondents were not aware of these appointments.
About the same, 25%
Better than average, 22%Worse than average, 34%
Not Applicable -I only apply for
permits in Palo Alto, 19%
How does Palo Alto's Permitting Process Compare to
Other Jurisdictions?
26
The survey included a number of opportunities for respondents to share additional comments, thoughts, etc. The following provides a high-level summary of the
general themes of these comments, based on the OCA’s examination:
• An overall lack of timeliness dominated the open-ended comments received from respondents. Comments mentioned permit process taking a significant
amount of time and corresponding issues such as project delays and costs. Length of time to obtain an inspection was mentioned throughout as well. In
addition, a number of comments mentioned length of time to get a response to questions, clarifications, etc. – and also a general lack of communication
from the City was cited.
• Lack of clear guidelines and too much complexity was another commonly cited complaint and area of need for improvement by respondents. Frustration in
being able to obtain/understand what was needed for an application was mentioned numerous times. Respondents also mentioned rules/processes being
overly complex and difficult to understand, in addition to OPS being difficult/complex to navigate.
• Customer service-related issues were mentioned throughout the comments as well. In addition to lack of response from staff, respondents stated that
some staff were poorly equipped to answer questions and that the consistency from one staff to another in similar titles also varied widely. In addition,
respondents mentioned need for better interactions with staff – citing suboptimal customer service from both project coordinators and inspectors.
In addition, the OCA examined responses based on type of permit applied for, time frame and frequency of application and other respondent characteristics to look
for any correlation. Based on this examination, we found:
Yes, 41%
No, 59%
Were You Aware of Palo Alto's Development
Center offering In-person Building Permit
Application Assistance?
27
• For respondents seeking a solar permit, they were overall more dissatisfied with their experience – with a much higher rate of extreme dissatisfaction, in
particular. In terms of comparison, these respondents also felt the City’s process was worse than other organizations where they sought permits from –
but also indicated at a higher rate than all respondents that the process was overall comparable.
• In terms of frequency of application, those applying for permits on a weekly basis felt the City’s process was better in comparison to other organizations –
with a noticeable positive trend in favorable comparability the more a respondent issued permits with the City. This trend was also present when
respondents were asked about their overall satisfaction with the permitting process, with those having more frequent issuance of permits with the City
having a greater overall sense of satisfaction.
• In addition to frequency of applying, we also asked respondents when they had last applied for a permit. Respondents indicating they had applied for a
permit within the last week of completing the survey were generally more dissatisfied and felt the City’s process was worse overall than other
cities/jurisdictions where they had applied for a permit. However, those indicating they applied for a permit within the last month were overall more
satisfied and felt the City’s process compared more favorably. This could be an indication that the process may be perceived as being somewhat difficult
for those just having gone through the process, but not overlay difficult to leave a longer lasting negative perception. the negative experiences of applying
for a permit was top of mind.
Themes
Observations from OCA’s customer survey include:
• Majority of respondents applied for permits multiple times per year, with approximately one-quarter of respondents applying infrequently.
• Respondents skewed slightly negative in their overall perception of various aspects of the building permit process.
• Key areas of concern for respondents included:
o Length of time to issue a building permit or obtain an inspection was too long
o Guidance provided on-line was either lack or not clear
o Customer service was often lacking – both in terms of responsiveness and helpfulness
• Areas that respondents would like to see improvement of the building permit process included the online permitting process and turnaround time from
application to permit.
• For the inspection process – respondents would like to see improvement in wait time between request for inspection and actual inspection.
• Open ended responses focused extensively on frustration with length of process overall
28
Building/Contractors Associations Feedback
Overview
The OCA reached out to a number of local professional associations across building industry types to try and gather additional opinions and insights into the permit
and inspection processes in the City. The following is a list of associations we contacted:
• Bay Area Building Industry Association
• Associated General Contractors, South Bay District
• American Institute of Architects – Silicon Valley Chapter
• California Solar & Storage Association
Only the California Solar & Storage Association ultimately provided names for the OCA to speak with. However, responses from those individuals was extremely
limited. Individuals that were willing to have correspondence with the OCA were skeptical of efforts to improve the permit and inspection process in the City and
highly critical of the current process.
In addition to these associations, the OCA was also provided with contact information for other contractors. The contractors we spoke with were more willing to
offer insights, but again, in general, were highly critical of the process in the City.
Themes
The following is a high-level summary of themes from these conversations:
• Long wait time for permit approval
• Inconsistency in experience and knowledge of inspection staff
• Inspectors requiring additional work above and beyond what the approved project plan outlines
• Requirements well above and beyond what is considered ‘best practice’ from surrounding jurisdictions
• Other contractors refusing to work in Palo Alto or charging premiums for projects in City
Concerns with the permit and inspection processes are also expressed in articles and reader comments from the local newspaper, Palo Alto Online , with themes
similar to those expressed above and from the broader customer survey conducted by the OCA.
Photovoltaic Code Review and Benchmarking
Overview
The OCA completed research on comparable cities to understand the similarities and differences in their photovoltaic (PV) permitting requirements. The permitting
process for PV projects have been a more common topic of conversation for the City for a number of reasons. Historically, the process to receive a permit for a PV
project has been difficult according to interviews though many improvements have been made since. Additionally, the OCA also heard during interviews that many
of the individuals or organizations applying for PV-related permitting may not have as much experience with the City’s process as experienced builders and
architects applying for traditional permit types. These factors encouraged the OCA to conduct research into the PV requirements for comparable cities.
Overall, all of the comparable cities had similar requirements as the City of Palo Alto. This is likely due to each comparable city basing their requirements on State
statutes. Even checklists and guides are similar between cities, including Palo Alto. One unique element of Palo Alto is their ownership of their utilities. Like other
29
cities, Palo Alto requires both a permit to build and to connect to the grid. However, seeing as Palo Alto owns its own utility, this could be a more efficient,
collaborative approval process.
In addition, the OCA examined each of the comparable cities to look at their current practices for issuing permits and requesting inspections. Most all of the cities
are handling permits electronically only and scheduling inspections via apps, website or phone. In addition, we examined their websites, including available
information and on-line submission tools, to examine their practices in relation to the City of Palo Alto. In general, information in other cities was more readily
available and accessible in intuitive formats.
30
Photovoltaic (PV) Benchmarking Summary
The OCA worked with the PDS staff to create a list of comparable cities (whether by geography, size, or both). The information below summarizes peer cities’
photovoltaic permitting process and links to their codes.
City Base of Code Similarities/Differences Notes Link to Code
Palo Alto Primarily based on State statutes N/A, See Below Palo Alto Municipal
Code
Los Altos Primarily based on State statutes Only one inspection is required for Los Altos residents Los Altos Municipal
Code
Menlo
Park
Primarily based on State statutes Contains a clear checklist for applicants
Initial inspections are included in the new building initial building inspection,
saving applicants a step
Menlo Park Municipal
Code
Mountain
View
Primarily based on State statutes City utilities are private entity, which provides less control for the city Mountain View
Municipal Code
San Jose Primarily based on State statutes Has additional requirements for PV panel weight, height, load, etc. that is
not required by the City of Palo Alto
Provides a clear one-pager of critical information for applicants
San Jose Municipal Code
Sunnyvale Primarily based on State statutes, but
rewritten in laymen’s terms
Similar to Palo Alto in a “one-stop shop” idea, as in all permits are issued
from the building department
Sunnyvale Municipal
Code
While there was discussion in interviews around the difficulty of PV permitting in particular, the difficulty is not particular to the code itself. As mentioned, the code
is largely standard language taken from State statutes. If the State statutes were unnecessarily cumbersome, Palo Alto would not be in any better or worse
position than any other neighboring cities.
31
Summary of Additional Findings from Comparable Cities
In addition to the review of building code, the OCA also examined items of interest as to how the building and inspection processes are structured in the
comparable cities and any significant, recent changes. The following is a summary of these findings by comparable city.
City Summary of Significant Information Source(s)
Los Altos • Building Department opened back up to public on October 18, 2021
• City requiring all plans be submitted to an email address beginning April 2021 – no hard copies accepted.
• Checklists/submittal instructions readily accessible on single page of website (with reference to other depts, as
necessary) –
• City uses eTRAKiT to schedule inspections
Los Altos Building Services
Menlo Park • Permits being accepted through on-line portal (through Accela), process includes a pre-application step before
conversion to a building permit application.
• In-person meetings by appointment only
• No over the counter reviews available
• Number of forms, guides and FAQs readily accessible on Building Division’s home page
• Expedited plan check – but not well advertised
• Inspections can be scheduled by phone or on-line via the Accela portal
Menlo Park Building
Division
Mountain
View
• Public Counter in Building Division by appointment only – schedule on-line for a 20 minute session (TimeTap
program)
• Plans can be submitted electronically Monday- Friday between 8am-4pm
• A number of forms and handouts available on website – several clicks to find
• Inspections scheduled on-line via an Epermits page
Mountain View Building
Division
San Jose • In person appointments available, but geared to those with lack of access to internet or other technical challenges
• Website includes a number of walk-throughs/checklists to detail when ‘simple’ project permits can be used, as
well as other permit types
• Encourage using their sjpermits.org site by waiving portion of fees ($48)
• Have expedited review for certain projects
• For fiscal year 2022 budget, reduced Development Services Imaging and Call Center intake staffing by 11 positions
due to process and technology improvements. Funds re-allocated to ADU Ally program and environmental
reviews.
San Jose Development
Services Permit Center
San Jose 2021-2022
Adopted Operating Budget
(see page 730)
San Jose Organizational
Charts
Sunnyvale • Permit center open to public five days a week
• Plan check available in morning, by appointment
• Can submit on-line – however, website advises calling a planner to discuss project prior to filling out any forms or
submitting
• On-line portal fairly rudimentary – but in check box format for type of quick permit requested includes detailed
guidelines/checklist for each type – instructions not as clear for permits requiring plan check
Sunnyvale Permit Center
32
City Summary of Significant Information Source(s)
• Inspections can also be scheduled through on-line portal
Themes
The following is a high-level summary of themes from this review:
• PV/Solar codes for comparable cities follow State statutes fairly closely.
• Some comparable cities review/processes for PV/solar projects have more clear guidelines and checklists than the City of Palo Alto – which is also
generally true for information available on a broader basis.
• Comparable cities mostly on-line/virtual only for current permitting processes.
• Comparable cities also offering in-person meetings, generally by appointment only.
33
Audit Results
This section summarizes the results of our analysis and offers recommendations for improvement, Of note, the recommendations provide overall suggestions for
improvement for the building permit and inspections processes for all types of building permits. Initially, the OCA was tasked with examining two permit types;
however, after initial analysis, the OCA determined that permits generally follow the same process regardless of type. Regardless, the OCA’s recommendations
outline significant opportunities for improvement, as noted more specifically in the following.
For each observation and recommendation, we have also provided a high level assessment of potential impact for PDS of implementing the recommendation and
the significance of potential barriers to implementing the recommendation. The assessments are ranked on a scale of high, medium and low – with the following
serving as definitions for the ranking category:
• High: High level of impact to the organization, with a low or medium barriers to implement
• Medium: Medium or high level of impact to the organization, with medium or high barriers to implement
• Low: Medium or low level of impact to the organizations, with medium or high barriers to implementation
34
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
1 Inspection Lead Times
The lead time for a building
inspection is approximately
two weeks from request to
inspection.
As noted by staff throughout
PDS, lead times have shown
recent improvement decreasing
from what was a 2 week wait
from request to actual inspection;
however, such improvements are
precarious with any staff absence
– whether planned or due to
injury, etc. that can quickly erode
any improvement to lead time.
According to interviews with PDS
staff, contract inspection staff
have been difficult to obtain,
particularly after the start of the
pandemic. Long lead times result
in a host of compounding issues,
with contractors scheduling
inspections far in advance of
work being completed – resulting
in either inspectors arriving
before work is complete or re-
scheduling of appointments. This
is confirmed by the Building
Permit Data Analysis section’s
examination of inspections
requested – with 18% of
inspections requested being
cancelled. Inspection lead times
were also noted as one of the top
areas for need for improvement
by building permit customers in
survey responses.
The OCA recommends hiring
additional staff and implementing
efficiency measures to improve
permitting and inspections cycle
times.
The City should make "improvement
of lead times" (i.e. the length of time
between inspection request and
actual inspection) one of the top
priorities for improvement in the
building permit and inspection
processes. A number of changes can
be implemented to help improve the
lead times, including:
1. 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.
2. Find additional efficiencies with
current staff, including assigning
geographic areas to Inspectors to
reduce travel time and possibly
assigning inspections by specialty
3.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.
4. Consider third party plan review
1.
High 2. Med 1. High
35
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
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).
5. Consider the role of a lead
inspector/field supervisor to help with
training, quality control, and other
duties that would assist inspection
manager
36
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
2 Customer
Service/Accessibility
Customers/applicants need
better information on all
aspects of the permitting and
inspection process.
Applications require a pre-review
(pre-application) and first review
which was noted by PDS staff as
being confusing to the applicant.
Second, many applications are
incomplete, often due to lack of
understanding by applicants as
to what information needs to be
included. This requires back and
forth between PDS and the
customer to obtain the correct
information for the application to
proceed through the review
process. Checklists, forms and
related documents can be
difficult to locate on the website
and also are organized more by
department than project/permit,
which may not be readily intuitive
for applicants. .
Survey responses confirm
difficulty to find forms and follow
what is required for an
application. Lack of clarity of the
process was mentioned by a
quarter of those leaving open
ended responses (approximately
150 respondents) third only to
need for quicker turnaround
times and need for better
customer service/responsiveness
from PDS staff.
Per PDS staff, applicants also
can be confused as to what type
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.
While the City has created a number
of documents and guides to help
customers through the permitting
process, customers may not know
that those guides exist. The City
should reference all guides, videos
and other aids throughout the
process in the OPS system and in-
person. This will allow customer to
understand what reference materials
are available to aid in the process.
This is also true of documentation
impacting the process from other
departments, such as Utilities, Urban
Forestry, Public Works, etc. –
information should be presented in
multiple places on the website and in
OPS to ensure that applicants have
multiple touch points to access and
digest relevant information to help
improve the overall quality of
applications submitted and to best
inform the applicant.
In addition, PDS should develop a
‘frequently asked questions’ (FAQs)
resource on its website and widely
communicate it through various
channels to help stem some of the
questions being emailed and called in
directly to staff. This FAQ section
could also serve then as a longer
2. Med 2. Med 2. Med
37
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
of inspection to request. This is
likely due to there being
incomplete guidance provided on
PDS website – particularly
related to final inspections. ––
range repository of information
regarding the permit and inspection
processes going forward.
PDS needs to examine how capacity
constraints may impact their ability to
make these improvements (and also
in Recommendations 3, 6, 7, 9 &10).
This could include repurposing of
current staff/functional titles, hiring
additional staff, and/or hiring
consultants to support efforts to
improve accessibility, functionality,
and the application process, in
general. However, PDS needs to
consider its longer-term operating
model as a part of this, i.e. on-line,
counter service or a hybrid approach
(see Recommendation #8).
38
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
3 Guidance/Forms/Checklists
A number of the forms,
guidelines, and checklists
provided on PDS’s website
date from prior use of the OPS
system.
While most of the more technical
information is likely still pertinent,
information on how to submit
applications and associated
information through OPS are not,
as PDS did not intake any
applications electronically pre-
pandemic. While a large amount
of information is available on-line,
its accuracy for the change to
OPS could prove problematic for
less informed or frequent users,
in particular. ’For example, PDS’s
‘Single Family Residential
Construction Guide’ has links
throughout – more than half of
which refer back to a City web
page that no longer exists. In
addition, this document still
references the ‘in-person’
permitting process throughout,
including references to
submitting paper plans. Per city
staff, t applicants knowingly
submitting incomplete
applications and relying on PDS
staff to then outline what the
applicant needs to submit, likely
driven in part by the lack of up to
date and readily accessibly
information.
The OCA recommends modifying
OPS to incorporate relevant
information and present in more
intuitive format.
As touched on in Recommendation 2,
reference materials should be better
integrated into OPS at each relevant
stage the process. Applicants should
be able to have a hyperlink to a video
or checklist at each point in the OPS
process. For example, at each point
applicants attach documents, the
OPS system should link to resources
regarding naming conventions. This
will cut down on questions from
applicants and will provide higher
quality applications overall. If
applications are done correctly, the
City will save time on resubmittals
and rereviews, especially in regards
to naming conventions for application
files. These reference materials will
also ensure as a check for project
coordinators as well – to ensure that
similar projects are all upheld to the
same standards in terms of
documentation requested and
ultimately provided.
See the City of San Jose’s Building
Division website as an example –
including for how forms are presented
in an applicant intuitive format here
In addition, PDS should present
information in a type of decision-tree
format that is more intuitive from an
applicant’s perspective – asking
specific questions to help guide the
applicant through the process and
2. Med 2. Med 2. Med
39
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
pointing applicants towards reference
materials to help answer more
commonly asked questions.
40
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
4 Permitting Process as an
Applicant’s QA Step
Applicants knowingly submit
incomplete information.
Applicants oftentimes use the
permitting process as a quality
assurance check on their
application. In other words, they
may be submitting applications
with awareness that it may be
sent back with a summary of
everything that's missing. Ideally,
applicants are utilizing the
resources provided to the
applicants to send in as complete
of an application as possible.
Instead, using the permitting
process as a quality assurance
(QA) step for applicants is a
burden on City resources.
The OCA recommends to
providing better guidance
resources and rejecting any
incomplete applications.
Please refer to Recommendations #2
and #3 for details regarding providing
guidance/resources on OPS for
applicants. PDS staff need to more
proactively reject applications that are
grossly incomplete or inaccurate and
point applicants back to on-line
resources (as improved in other
recommendations in this report). This
primarily resides with the project
coordinators thoroughly reviewing
submissions (aided by better training
for consistency as mentioned in other
recommendations as well). A high
level of customer service in these
communications is necessary and
also inclusion of a reminder that
incomplete applications increase
review time for all applications.
2. Med 2. Med 2. Med
41
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
5
Communications between
Project Coordinators and
Departments
Requirements for pre-
application/application plan
review and permitting are not
always clear.
Departments involved in the
building permit and plan review
processes noted inconsistencies
between Project Coordinators in
informing the departments as to
whether or not a pre-
application/application required
their review. In some interviews,
the OCA learned of departments
being pulled into the review
process much later than others.
This leads to potential delays for
the applicant, quicker turnaround
times for the department brought
late to the table, and also
potential significant costs for the
applicant if the omission impacts
inspection process requiring
significant project changes.
Departments also noted that
communication is inconsistent
depending on project
coordinator, particularly as
related to high profile or
expedited projects.
The OCA recommends improving
notification for all involved
departments of pending reviews
simultaneously at the pre-
application stage.
During the pre-application phase, all
pre-check requests should be sent to
all departments simultaneously.
Currently, this is being done manually
by the project coordinator with
guidance from an MS Excel based
workflow. Ideally, this can be
automated in OPS as a function of
the workflow. This ensures that
departments have adequate time to
review the pre-application and
provide a consistent timeline for each
pre-application. Department
deadlines should remain consistent
as well, ensuring all departments are
held to a consistent expectation for
turnaround times. Communication
protocols should also be actively
reviewed and included in developing
Standard Operating Procedures
(SOPs) as further outlined in these
recommendations. Review of SOPs
should also ensure that a complete
list of which department needs to
review what type of permit/project is
developed.
2. Med 2. Med 2. Med
42
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
6 OPS Functionality
PDF forms required by OPS,
including the building permit
application, do not always
provide sufficient information
for review.
OPS provides applicants the
ability to attach PDF forms as
opposed to entering information
directly into the system, including
the actual building permit
application and other supporting
documentation/plans. Often, the
PDF forms submitted are missing
vital information. Additionally,
many applicants may not be
familiar with everything that is
required of them in these permit
applications. OPS doesn’t
provide the guidance for
applicants to ensure that each
step of the process is clear, given
their specific circumstances, or
ensure that applicants are
providing all necessary
information field-by-field.
Information on the City’s website
is segregated by department as
opposed to providing a ‘one-stop
shop’ for information that may
pertain to applying for a permit.
The OCA recommends digitizing
data collection from PDF to
directly in the OPS system to
ensure that all relevant data is
captured.
The main function of OPS at the
moment is attaching documents in a
guided process. However, the City
could strive to have OPS contain
much of the vital information in
separate fields (i.e., having the
application itself be an on-line fillable
form) to avoid errors in submissions
and resubmissions. Additionally, for
fields that need to be edited,
applicants could edit only those fields
without having to attach an entirely
new application.
2. Med 2. Med 2. Med
43
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
7 Policies and Procedures
PDS does not have a shared
and consistent set of Standard
Operating Procedures (SOPs).
Many SOPs are documented via
email or team members instead
rely on institutional knowledge.
This creates the potential for
variances in applicant
experiences in regards to the
permitting and inspection
processes. Additionally, it does
not provide a living, single source
of truth on which PDS can rely
and reference and also train new
staff from.
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.
When developing Standard Operating
Procedures (SOPs), it is important to
view these as living documents. In
other words, SOPs should contain
the current practices, and also should
be updated and refined as PDS
learns of new and better practices in
regards to the permitting system. It is
also important that these SOPs are a
helpful guide to employees who may
be learning a new skill or process.
SOPs should be readily accessible
and available to staff throughout PDS
as a reference guide. A clear process
should also be developed in terms of
regularly updating and reviewing the
SOPs, including a process for
incorporating changes and
suggestions from staff throughout the
department. Updating of policies and
procedures will be of particular
importance to help codify
recommended process improvements
within this report.
2. Med 2. Med 2. Med
44
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
8 Need for Updated Strategy
PDS is operating under an
outdated initiative for the
operation of its building permit
function.
The Development Center was
established in July 2011, as
recommended in the ‘Blueprint
for a New Development Center’
in July 2010. This plan created
the current counter service model
and was driven by a need to
increase customer satisfaction
and expedite permit issuance.
While the model has helped to
improve cooperation between
departments and provide a one-
stop-shop for applicants, the
blueprint was developed prior to
any permits or intake of
information being done virtually.
Some of the key tenants and
goals of the blueprint are still
relevant; however, consideration
should be given as to how the
digital dissemination and
availability of information could
change both the interface with
the applicants and also how
coordination between
departments actively involved in
the permitting process takes
place.
The OCA recommends PDS
develop an updated strategic plan
reflecting current realities and the
lessons-learned throughout the
pandemic.
PDS needs to develop a new
strategic plan in order to inform its
operations. A new strategic plan
should include guidance on
department structure, along with a
mission/vision statement for PDS and
include goals with associated
performance metrics. The Blueprint
was adopted over a decade ago and
while a number of the objectives
outlined within this plan remain
relevant, a ‘re-think’ of how the
Development Center and associated
processes are structured is
necessary. The need to re-fresh the
plan is of particular evidence with the
processes shifting to a much more
virtual dependent format due to the
pandemic. While the adjustment was
a heavy lift – the move to an on-line
process has seen benefits both for
applicants and staff in terms of
convenience and coordination. PDS
should build upon the switch to the
virtual application to guide its strategy
and priorities. The plan should be
done in conjunction with the City
Manager and Council to ensure
broad input and incorporation of
needs from the community –
including not only residents, but
building industry professionals as
well. This new plan should also than
serve as a roadmap for a number of
other recommendations within this
2. Med 2. Med 2. Med
45
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
report – particularly those related to
staffing and structure of the
permitting and inspection processes.
In addition, the plan needs to reflect
the current initiatives of the City –
with particular attention to
photovoltaic/electrification goals.
Development of a new strategic plan
and the process to do so is a
significant time investment. As such,
OCA recommends having preliminary
conversations with the City Manager
and Council to best address shorter-
term direction and corresponding
needs, particularly related to service
delivery model and potential staffing
impacts (as previously referenced in
Recommendation #2).
46
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
9 Need for Further Technology
Improvements
Technology challenges impede
plan review and permitting
processes.
A number of staff noted that
Accela/OPS is often slow and
adds wait time for their tasks
while the system re-freshes,
loads, etc. Also, it was noted that
the system is unavailable
regularly for system updates.
Some features of the software
are also suboptimal - such as the
ability to quickly bookmark and
reference plans uploaded into the
system. In addition, the DigEplan
add-on to Accela that enables
electronic plan review was done
quickly in response to the
pandemic and push to work
remotely, with some noting there
may be a better system available
to meet the City's needs. PDS
was starting a test pilot of the
DigEplan software as the need to
shift to remote work happened.
The OCA recommends that PDS
continues exploring technology
enhancements and better
platforms
PDS should continue to make strives
to improve functionality of
Accela/OPS. Efforts should be made
to coordinate system updates outside
of regular working hours to minimize
impact on staff. PDS should also
explore whether or not DigEplan is
the best solution going forward as
well - particularly related to
ability/need to bookmark plans for
ease of review. Future system needs
should be informed and aligned with
an updated strategic plan for the
permit and inspection processes to
ensure functionality and ease of
access for staff and applicants.
In addition, PDS should continue with
efforts to stream line the permitting
process by utilizing products such as
SolarAPP+. PDS is in conversations
to possibly utilize the product, and
OCA strongly encourages to move
towards implementation of
SolarAPP+ or a similar product.
2. Med 2. Med 2. Med
47
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
10 Training - Project
Coordinators and Inspectors
Project Coordinator training
needs improvement.
Inspectors need time for
training.
In interviews with departments
involved in the permitting
process, the need for better
training of Project Coordinators
was mentioned several times.
Project Coordinators did not
always provide or ensure all
required information was
obtained during the intake
process for the applications. In
addition, some departments
needing to be involved in the
plan check process were not
notified promptly to ensure
adequate time for the
department's review of their area
of expertise. Also, with lags in
building inspections, City
Inspectors are more constrained
for time in their ability to
seek/attend training to keep up
with relevant trends in the
building industry.
The OCA recommends PDS create
materials to train from and
prioritize time for training.
Training of staff should flow from the
development of Standard Operating
Procedures, with the SOPs serving
as a baseline of understanding for
staff, whether project coordinators,
plan checkers, department staff,
inspectors, etc. A regular schedule
for training should be developed as
well, in order for staff to share
particular issues they have had to
address and broader sharing of
knowledge/insights in general. In
addition, a regular training should be
held that includes all staff involved in
permitting and inspection processes -
both from PDS and the other
departments supporting, to best
share information, address concerns,
establish mutual understanding, and
build a broader sense of team work.
2. Med 2. Med 2. Med
48
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
11
Building Code Modifications
and Ability to Effectively
Administer
Palo Alto code modifications
increase the complexity of the
building plan review and
permitting process.
Per City and PDS staff and OCA
review, City building code
generally follows the State of
California Building Code.
However, some code
modifications unique to Palo Alto
have been added to the building
code to address specific
situations and other areas of
importance. The ability to
administer some of the
modifications to the code can be
difficult, as relayed in interviews
with PDS and particularly other
department staff and also from
applicant/customer feedback. In
addition, it was noted that the
frequency of modifications for
some portions of the code can
also make administration difficult
with trying to apply the updates
and track which version of the
code applies to permits based on
when the application was
submitted.
The OCA recommends that interim
code interim modifications are
limited as much as possible
Modifications to the building code
need to mirror the regular schedule of
updating the building code in line with
the regular cycle of updates down to
the State of California Building Code.
Any interim modifications should be
done only as necessary and if
involving a matter of serious concern
for public health, safety and general
welfare. As part of a strategic plan
update, criteria for what would trigger
making an interim modification should
be discussed with the City Manager,
PDS staff and Council to help
balance immediate need and ability
to implement/administer code
changes. Included should be
consideration for how changes will be
communicated to the public and also
contractors that may be impacted.
While additional up front time, this
communication may help offset
questions once a code change is
made.
2. Med 2. Med 2. Med
49
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
12 Quality Control
Quality control processes can
be strengthened.
Managers within the permit and
inspection processes have
concerns that the volume of work
has limited their ability to conduct
quality control - particularly
related to newer and contract
staff. Inconsistencies have been
mentioned by numerous City
staff interviewed as related to
how staff in similar titles perform
their responsibilities. The lack of
time and focus on quality control
exacerbates the ability to
consistently apply City processes
and in serving
applicants/customers - and in the
relative experiences of applicants
in navigating the processes as
well. Lack of consistency
amongst staff was also
mentioned throughout the open-
ended responses from the
customer survey.
The OCA recommends PDS place
a greater emphasis on quality
control and resources to help
promote it.
As included in previous
recommendations, the development
of SOPs, guidelines, checklists, etc.
will help with quality control and
consistency amongst Project
Coordinators and Inspectors. In
addition, management needs to be
proactive in creating performance
metrics that identify potential quality
control shortcomings and have
discussions with staff who may not be
meeting these expectations.
Performance metrics need to include
those that focus more on cycle times
for various aspects of both the permit
and inspection processes. This
should include examining the length
of time from application to approval;
inspection request to scheduled time;
overall length from application to final
inspection; and other relevant time
frames – and should be done across
permit types. Routine training, as also
mentioned in prior recommendations,
will also help in terms of improving
quality control.
2. Med 2. Med 2. Med
50
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
13 Staff Model - Contractor vs
City Employee
Difficulties in hiring and
retaining contract staff impede
departmental performance.
PDS has used both contract and
City staff for several key areas,
including plan review and
inspections. Due to the
pandemic, contract staff are
increasingly difficult to find and
also issues with not having the
same individual from a contract
company being available
(resulting in additional City staff
time to train, etc.). In addition it
was mentioned in a number of
interviews with City staff, that
there are continued
questions/concerns from the City
legal department about having
the same functions/roles
completed by City staff and
contractors. Also difficulty in
getting contract staff who want to
be in-person when things do
open back up. PDS management
staff have also stated a concern
of how to maintain quality control
for the work of contract staff.
The OCA recommends that PDS
develop plans to best
utilize/balance contract staff.
PDS should discuss and develop
plans for how to address its staffing
needs going forward. This should be
done in conjunction with development
of the aforementioned strategic plan
and the need for additional inspection
staff. PDS should be proactive in its
planning - particularly in relation to its
plan check staff. While the contracted
plan check staff have been fairly
stable, PDS needs to ensure that the
stability in this area continues and
also ensure quality and timeliness of
contractor's work as well.
In addition, OCA encourages PDS to
examine how its payment structure
and other requirements (including
reporting in-person) for contract staff
aligns with peer jurisdictions and how
this may impact PDS’s ability to
attract and retain contractors.
2. Med 1. High 2. Med
51
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
14 Vacancies and staff turnover
Turnover in key staff positions
constrains organizational
efficiency and effectiveness.
PDS has seen a fair amount of
turnover with the Assistant CBO,
Inspection Manager, and
Development Services Manager -
all new to their roles within the
last 2 years or less. The
Development Services Manager
is new to their role as of June
2020, with their predecessor only
lasting 9 months in the role. In
addition, the lead plan checker
role is being filled by the
Assistant CBO (a role he
previously filled). Staff turnover
has placed pressure on the
processes in general and also
requires additional time from
more veteran staff to train new
staff. Delays in City hiring
process can also compound the
impacts of staff resignations.
The OCA recommends developing
a strategic hiring plan for
recruitment and retention.
PDS needs to be proactive in terms
of retaining and attracting staff -
doing so in conjunction with priorities
it identifies as part of an updated
strategic plan. A hiring plan should
also address the balance and use of
contract versus directly employed
staff to address PDS needs.
Particular consideration is needed in
terms of the ability to utilize
contractors in key areas, given
challenges related to the market for
contract staff, In addition, PDS
management should carefully
examine the requirements/needs for
particular positions in hiring,
particularly as related to project
coordinators and management
positions. PDS has hired internal
candidates for several of these roles
over recent years.
2. Med 2. Med 2. Med
52
# Observation Title Summary of Observation Recommendation Impact Barriers to
Improvement
Overall
Priority
15 Unpermitted Work
Unpermitted building may
have increased during the
pandemic.
Concern has been expressed by
some PDS and City staff
interviewed that unpermitted
work may have increased do to
the pandemic, which may
account for some of the decrease
in permitting activity in the same
time frame (but also likely driven
by a decrease overall due from a
slow down/stoppage of work due
to the pandemic). Typically the
City has not patrolled to discover
unpermitted work, relying upon
residents reporting unpermitted
work and inspectors discovering
unpermitted work enroute to
inspections across the City.
Anecdotally, City staff stated that
unpermitted work may be 50%
higher than normal at the start of
the pandemic, but believe this
has decreased with the City
offering on-line permitting and
construction activity resuming
'normal' levels. If significant
unpermitted work may be
drastically lowering permitting
applications, the City may be at
risk for lost revenue and
improper building activities.
The OCA recommends that PDS
improve timeliness and
complexities of permit and
inspection processes to promote
compliance.
Recommendations 1, 2, 3, and 6 will
help greatly in reducing the time,
effort, and wait for
applicants/customers of the permit
and inspection processes. Some risk
of unpermitted work being performed
is offset by neighbors reporting any
unpermitted work. If the concern of
unpermitted work becomes
greater/more apparent - Inspectors
could be tasked with spending part of
their time canvassing the City while
enroute to scheduled inspections to
look for any work being done without
permits - but this may require
additional inspection staff given the
current inspection lead time.
3. Low 2. Med 3. Low
53
Appendices
Appendix A: Customer Survey
The following includes a complete list of the survey questions and associated options for respondents to pick from (if a multiple choice type question). Also, we
have included the responses for all questions that could be readily summarized and did not allow for open ended responses.
Here is the introduction to the survey and survey questions:
The City of Palo Alto is examining its building permit process – including permit application process and inspection process – to identify areas for improvement.
As a recent applicant for a building permit, we would greatly appreciate your time in completing this short survey to help better inform this analysis and guide
potential areas for improvement.
This examination is being led by the Office of the City Auditor as contracted to Baker Tilly US, LLP, an internationally-regarded advisory, tax, auditing, and
assurance firm (more information here - https://www.cityofpaloalto.org/Departments/City-Auditor).
1. What best describes your role in the permitting process?
a. Architect
b. Engineer
c. Commercial Contractor
d. Home Builder
e. Electrical Contractor
f. Plumbing contractor
g. HVAC Contractor
h. Solar Contractor
i. Homeowner
j. Other – please specify:
2. What type of permit(s) did you apply for (check all that apply)?
a. Residential – New Building
b. Commercial - New Building
c. Pool/Spa/Landscaping
d. Solar/Battery Storage/Other Photovoltaic Project
e. Electrical/Mechanical/Plumbing only
f. Addition/Remodel/Repair
g. Garage/Carport/Accessory Bldg
h. Deconstruction
i. Demolition
54
j. Direct 'Online' Permit (i.e. Repair Gas Leak, Boiler/Furnace/Water Heater Replacement, Re-
Roofing, Backflow Device, Window Replacement, etc.)
k. Other (if not included above)
3. When did you last apply for a permit?
a. Within the last week
b. Within the last month
c. Within the last 3 months
d. Within the last 6 months
e. Within the last year
f. More than one year plus ago
4. How often do you apply for building permits?
a. Weekly
b. Monthly
c. A few time a year
d. Annually
e. Infrequently
5. Were you aware the City of Palo Alto Development Center is offering in-person appointments for assistance in submitting a building permit application?
a. Yes
b. No
6. Did you use the in-person service or the on-line application process?
a. Pre-COVID, In-person/Counter service
b. Post COVID, In person, appointment
c. Online system
d. Post COVID – both in person and on-line
e. Something different – please indicate
7. Please rank the following from highest to lowest as to where you would like to the City focus its time and resources in improving the permitting process:
a. Online permitting process
b. In-person permitting process
c. Appointment availability for in-person permitting
d. Availability of staff for questions
e. Clarity of requirements
f. On-line resources/reference documents
g. Turnaround time from application to permit (cycle time)
h. Expedited permit for additional fee
8. Please provide any other additional comments/suggestions on the above ranking.
55
9. What is your perception of the following areas of additional steps and requirements related to the permit application and review process?
Very positive, Positive, Neutral, Negative, Very negative
a. Tree preservation and protection
b. De-watering requirements
c. Architectural review
d. Deconstruction and demolition
e. Utilities coordination
10. Provide additional comments on your above responses
11. Please rate your overall satisfaction with the permitting process
a. Extremely Satisfied
b. Somewhat Satisfied
c. Neither Satisfied or Dissatisfied
d. Somewhat Dissatisfied
e. Extremely Dissatisfied
12. What suggestions for improvement of the permitting process do you have?
13. Please rank the following from highest to lowest as to where you would like to the City focus its time and resources in improving the inspection process:
a. Wait time between request for inspection and actual inspection
b. On-site inspection visit
c. Clarity of inspector’s report/findings
d. Training/knowledge of inspectors
e. Reinspection wait time
f. Overall satisfaction with the inspection process
14. If you apply for permits in other jurisdictions, how does Palo Alto’s process compare?
a. Not applicable – I only apply for permits in Palo Alto
b. About the same
c. Better than average
d. Worse than average
e. Additional comments:
15. If you have any other additional thoughts – please feel free to share.
The following are the results that can be readily summarized:
1. What best describes your role in the permitting process?
56
67
3
23 20 8 16 17 4
42
50
Ch
o
i
c
e
C
o
u
n
t
Description
Describe Role in Permitting Process
57
2. What type of permit(s) did you apply for (check all that apply)?
69
19 17
62
104
25
12
25
36
47
Ch
o
i
c
e
C
o
u
n
t
Type of Permits
Type(s) of Permits Applied For
58
3. When did you last apply for a permit?
36
41
51
59
50
13
Within the last
week
Within the last
month
Within the last 3
months
Within the last 6
months
Within the last
year
More than one
year ago
Ch
o
i
c
e
C
o
u
n
t
Reason for Applying
When Did You Apply for Permit?
59
4. How often do you apply for building permits?
25
47
95
18
64
Weekly Monthly A few times a year Annually Infrequently
Ch
o
i
c
e
C
o
u
n
t
Frequency
How Often Do You Apply for Building Permits?
60
5. Were you aware the City of Palo Alto Development Center is offering in-person appointments for assistance in submitting a building permit application?
Yes, 41%
No, 59%
Were You Aware of Palo Alto's Development
Center offering In-person Building Permit
Application Assistance?
61
6. Did you use the in-person service or the on-line application process?
25
2
200
12 10
Pre-COVID, In-
Person/Counter
Service
During COVID, In-
Person/Counter
Service
Online System During COVID -
both in person and
on-line
Other-Please
specify
Ch
o
i
c
e
C
o
u
n
t
Service Uses
Use of In-person Service of On-line Application
Process
62
7. Please rank the following from highest to lowest as to where you would like to the City focus its time and resources in improving the permitting process:
a. Online permitting process
b. In-person permitting process
c. Appointment availability for in-person permitting
d. Availability of staff for questions
e. Clarity of requirements
f. On-line resources/reference documents
g. Turnaround time from application to permit (cycle time)
h. Expedited permit for additional fee
Aspects of Permitting Process 1st 2nd 3rd 4th 5th 6th 7th 8th
Online permitting process 66 40 37 32 20 15 5 7
In-person permitting process 21 25 23 26 31 39 46 11
Appointment of staff for questions 3 13 29 27 39 39 44 28
Availability of staff for questions 22 28 39 46 34 37 14 2
Clarity of Requirements 32 39 27 25 36 28 26 9
On-line resources/reference documents 6 12 27 29 23 37 43 45
Turnaround time from application to permit (cycle time) 68 44 20 23 19 6 33 9
Expedited Permit for additional fee 4 21 20 14 20 21 11 111
63
9. What is your perception of the following areas of additional steps and requirements related to the permit application and review process?
11. Please rate your overall satisfaction with the permitting process
30 37
137
19 182129
171
11 9
19
51
125
30
1620
54
143
15 9
29
48
127
18 19
0
20
40
60
80
100
120
140
160
180
Very Positive Positive Neutral Negative Very Negative
Ch
o
i
c
e
C
o
u
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t
Perception Options
Perception of Additional Permit Application Requirements
Tree Presearvation and Protection
De-watering Requirements
Architectural Review
Deconstruction and Demolition
Utilities Coordination
64
Extremely Dissatisfied, 19%
Somewhat Dissatisfied, 24%
Neither Satisfied nor Dissatisfied, 20%
Somewhat Satisfied,
25%
Extremely Satisfied, 12%
Overall Satisfaction with Permitting Process
65
13. Please rank the following from highest to lowest as to where you would like to the City focus its time and resources in improving the inspection process:
a. Wait time between request for inspection and actual inspection
b. On-site inspection visit
c. Clarity of inspector’s report/findings
d. Training/knowledge of inspectors
e. Reinspection wait time
f. Overall satisfaction with the inspection process
119
60
29
13 12 4
36
72 64
40
18
7
22
31
76
64
36
8
18 16 23
77
68
35
8
41
27 28
81
52
34
17 18 15 22
131
0
20
40
60
80
100
120
140
1st 2nd 3rd 4th 5th 6th
Ch
o
i
c
e
C
o
u
n
t
Ranking 1 Highest -6 Lowest
City Focus of Resources to Improve Inspections
Wait time between request for inspection and actual inspection
On-site inspection visit
Clarity of Inspector's report/findings
Trainings/Knowledge of Inspections
Reinspection wait time
Overall satisfaction with the inspection process
66
14. If you apply for permits in other jurisdictions, how does Palo Alto’s process compare?
About the same, 25%
Better than average, 22%Worse than average, 34%
Not Applicable -I only apply for
permits in Palo Alto, 19%
How does Palo Alto's Permitting Process Compare to
Other Jurisdictions?
67
Appendix B: Management Response
PDS provided responses to each recommendation. The OCA will perform periodic follow up to understand what actions have been taken to remediate the matters
identified in this report. Results of that follow up will be communicated to the Policy & Services Committee and subsequently to City Council.
68
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.
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.
69
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.
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.
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.
70
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.
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.
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.
71
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.
72
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.
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.
73
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.
74
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.
75
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.
76
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.
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.
77
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.