Residential Permitting

Four photos of houses in various stages of construction.

Objective

To determine how effectively the Department of Community Planning and Development manages the city’s residential permitting process to ensure it meets its mission and goals to ensure safe and sustainable building by completing permit application reviews on time.

Background

The Department of Community Planning and Development’s residential plan review team reviews project plans and issues permits for one- and two-unit residential properties and checks for compliance with Denver’s building and zoning codes. The reviews ensure land use, design, and construction standards are met for residential construction projects.

The city saw a large increase in permit applications during and after the COVID-19 pandemic as homeowners began remodeling their homes. Because of this, the number of plan reviews completed on time has decreased.

Why this matters

Without written processes, city staff cannot ensure plan reviews are done consistently, accurately, and in a timely manner. This can result in project delays and increased costs on homeowners. And without consistent analyses with reliable data, Community Planning and Development cannot ensure it has adequate resources to meet the demand for permits.

Findings

FINDING 1 — A lack of manager oversight and documented processes delays review times

  • City staff and contractors lack a formal training process and manager oversight to ensure plan reviews are done accurately and consistently.
  • The Department of Community Planning and Development does not have formal processes to communicate with homeowners, construction contractors, or other agencies’ permit review teams.
  • The department’s residential plan review team does not have reliable data to determine whether it is achieving its goals.

FINDING 2 — The residential plan review team needs more consistent, reliable data to effectively allocate staff resources

While Community Planning and Development has conducted staffing analyses for the residential plan review team in the past two years, staffing analyses are not done consistently and the data used to determine staffing needs is unreliable.

Recommendations

1.1 Develop a formal training plan – The Department of Community Planning and Development should develop a written, formal training plan for the residential plan review team that, at a minimum, specifies:

  • The types of training required and how often each training should be taken after a staff member is hired (e.g., once, annually).
  • How training will be tracked and documented.
  • Which staff member is responsible for tracking and documenting training.
  • How often the training plan should be reviewed and updated.
  • Requirements for individual training plans that ensure a focused approach to staff training and development needs.

Agency Response – Agree, Implementation Date – March 1, 2024

1.2 Review, update, and finalize training guidance – The Department of Community Planning and Development should review its training documents and guidance for the residential plan review team to determine what information should be included in the training plan. The training plan should then be updated and finalized.

Agency Response – Agree, Implementation Date – March 1, 2024

1.3 Written guidance for oversight and monitoring – The Department of Community Planning and Development should develop and document written policies and procedures for how to oversee and monitor plan reviews completed by the residential plan review team. These documents should specify the types and frequency of oversight, who should conduct the oversight, and how it should be documented.

Agency Response – Agree, Implementation Date – June 28, 2024

1.4 Develop policies and procedures for monitoring contracted staff – The Department of Community Planning and Development should develop and implement policies and procedures for how it will monitor all requirements in contracts with third parties that support the city’s residential plan reviews.

Agency Response – Agree, Implementation Date – March 29, 2024

1.5 Appoint a contract administrator – The Department of Community Planning and Development should appoint a contract administrator or dedicated staff member to oversee contracts with third parties that support the city’s residential plan reviews and ensure that all elements of the contract monitoring policies and procedures developed in Recommendation 1.4 are met.

Agency Response – Disagree

1.6 Develop and implement policies and procedures for website updates – The Department of Community Planning and Development should develop and implement policies and procedures to periodically evaluate and update online guidance related to the residential plan review process to ensure it aligns with current practices.

Agency Response – Agree, Implementation Date – Feb. 29, 2024

1.7 Identify and document applicant guidance in need of improvement – The Department of Community Planning and Development should work with its communications team to identify and document areas where the department may improve applicant guidance for the residential plan review process by streamlining the department’s website and simplifying language and instructions about submittal requirements.

Agency Response – Agree, Implementation Date – April 30, 2024

1.8 Revise guidance and templates for plan review notices – The Department of Community Planning and Development should revise its existing guidance and templates for information required in plan review notices to ensure plan reviewers are communicating resubmittal requirements thoroughly and consistently.

Agency Response – Agree, Implementation Date – March 29, 2024

1.9 Develop and implement policies and procedures for communication across review teams – The Department of Community Planning and Development should work with all review teams involved in the residential permit review process to develop and implement policies and procedures for how and when various teams should be communicating.

Agency Response – Agree, Implementation Date – March 29, 2024

1.10 Determine resource needs for answering applicant questions – In conjunction with Recommendation 2.1, the Department of Community Planning and Development should determine whether it has the necessary resources or needs additional resources for dedicated staff to answer applicants’ questions on the permitting process.

Agency Response – Agree, Implementation Date – June 28, 2024

1.11 Develop and implement policies and procedures for reviewing and incorporating feedback – The Department of Community Planning and Development should develop and implement policies and procedures to periodically review applicants’ feedback, track trends, and evaluate how feedback should be used to improve existing residential permitting processes.

Agency Response – Agree, Implementation Date – June 28, 2024

1.12 Develop and implement guidance to address inquiries and escalations – The Department of Community Planning and Development should develop and implement written guidance for how the residential plan review team should address applicants’ inquiries and escalations.

Agency Response – Agree, Implementation Date – Feb. 29, 2024

1.13 Limit user access in Accela – The Department of Community Planning and Development should limit staff’s user access to specific functions in Accela — to prevent errors arising in the permitting process — including restricting access to the intake queue to only the necessary team members.

Agency Response – Disagree

1.14 Revise training and guidance for intake staff – The Department of Community Planning and Development should document and revise existing training and guidance to ensure its intake team has the necessary information to accurately determine which reviews are needed for residential permit applications.

Agency Response – Agree, Implementation Date – June 28, 2024

1.15 Document and implement policies and procedures to determine data reliability – The Department of Community Planning and Development should document and implement policies and procedures to periodically evaluate the residential plan review team’s data and dashboards to ensure the data is reliable and meets the team’s objectives. This process should also include identifying data reliability issues and solutions to address any identified issues.

Agency Response – Agree, Implementation Date – Feb. 29, 2024

1.16 Review and update the programming code – In conjunction with Recommendation 1.15, the Department of Community Planning and Development should periodically review and update the programming code used to create the residential plan review team’s internal and public dashboards to ensure the data is accurate and aligns with current department practices. This process should be documented.  

Agency Response – Agree, Implementation Date – March 29, 2024

1.17 Obtain and review documentation on Accela fields – The Department of Community Planning and Development should obtain and review Accela documentation on how fields are populated in the system, including the “due date” and “task status date” fields.  

Agency Response – Disagree

1.18 Work with Accela to fix errors – The Department of Community Planning and Development should work with Technology Services and Accela to fix the scripting errors that are causing duplicate entries in the system.  

Agency Response – Agree, Implementation Date – Dec. 31, 2024

2.1 Develop a formal workforce plan – The Department of Community Planning and Development should develop a formal workforce plan that addresses the need to maintain adequate resources for the residential permitting process. This plan should align with the department’s mission, goals, and objectives and include:

  • Data elements used to assess workforce needs (e.g., permit volumes, workloads, and trends).
  • Strategies to address gaps in resources.
  • Time frames for implementing strategies.
  • Steps and tools for measuring success, including time frames.
  • How often to reassess and revise the workforce plan.

Agency Response – Agree, Implementation Date – Dec. 31, 2024

2.2 Formally evaluate data – In conjunction with Recommendation 1.15, the Department of Community Planning and Development should conduct and document a formal evaluation of residential plan review team data used to make staffing decisions and determine how to address any data reliability issues or data limitations identified.

Agency Response – Agree, Implementation Date – March 31, 2024

Auditor's addendums

Auditor’s addendum to agency response for Recommendation 1.5

As we discuss on page 15, Community Planning and Development managers said they do not have a designated contract administrator for the Bureau Veritas contract and thought the residential plan review team should have a designated staff member to monitor the contract and track compliance with its requirements.

The department does have one manager responsible for billing Bureau Veritas as well as multiple leaders in the department and on the residential plan review team designated as points of contact for the contract.

Additionally, managers designated a senior staff member from the residential plan review team to perform “light” quality control reviews to verify procedural items on Bureau Veritas’ permit application reviews, but one team manager said they must choose what they will monitor from the contract.

Therefore, we maintain that appointing an official contract administrator for this contract would help the department better enforce all contract requirements as specified in Recommendation 1.4.

Auditor’s addendum to agency response for Recommendation 1.13

We believe the Department of Community Planning and Development’s response meets the intent of this recommendation. As the recommendation says to restrict access to the intake queue to only necessary team members, we think this would allow residential plan review team staff and supervisors to maintain access to this queue while potentially restricting access to review teams in other city agencies. However, we are encouraged that the department is looking for other ways to prevent review tasks from accidentally being removed from the intake team’s queue.

Auditor’s addendum to agency response for Recommendation 1.17

While we were provided with the “Data Dictionary of Common Accela Automation Fields” during the audit, the data dictionary does not contain descriptions of what information is stored in the “due date” and “task status date” fields or how they are populated.

However, we were not provided with or told about any back-end server tables when we asked whether the department has a data dictionary for Accela. Members of Community Planning and Development’s data team said the current data dictionary is old and outdated and that the department did not have any other documentation explaining how the “due date” or other fields in Accela are populated.

As we discuss on page 41 of the report, leading practices say organizations should ensure all aspects of their information systems are documented for consistency.

Auditor's Letter

January 18, 2024

We audited the residential permitting process in the Department of Community Planning and Development to determine whether it is effectively managed to meet the department’s mission, goals, and objectives. I now present the results of this audit.

The audit found that a lack of consistent, documented processes and unreliable data contributed to longer permit review times. Additionally, inconsistent staffing analyses and unreliable data does not provide department leaders with the necessary information to determine if they have sufficient resources to address permit volume and develop formal processes.

By implementing recommendations for stronger policies for oversight and data reliability, the Department of Community Planning and Development will be better able to ensure permit applications are reviewed and approved consistently and in a timelier manner.

However, I am disappointed the Department of Community Planning and Development chose to disagree with recommendations that would allow the department to better monitor contract requirements and ensure more reliable data.

This performance audit is authorized pursuant to the City and County of Denver Charter, Article V, Part 2, Section 1, “General Powers and Duties of Auditor.” We conducted this performance audit in accordance with generally accepted government auditing standards. 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.

We appreciate the leaders and team members in the Department of Community Planning and Development who shared their time and knowledge with us during the audit. Please contact me at 720-913-5000 with any questions.

Denver Auditor

Auditor's Signature
Timothy O'Brien, CPA


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AUDITOR TIMOTHY O'BRIEN, CPA
Denver Auditor


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