The 'Small Project' Burden

A lot’s been made in the past 2 decades of ‘simplification’ of the permit process. Most cities in the County have either refined their list of submitted items and procedures of review, or created new items and procedures; all formed in the interest of ‘simplicity and efficiency’. This refinement is not without its benefits. Private parties (homeowners, designers, and other consultants) have the luxury of clear and concise checklists. With the right mix of knowledge and patience (and money), a person submitting a package for a building, discretionary, grading, administrative, or other permit can eventually create all the elements being called for. Coastal Development Permits can contain nearly all the same elements and requirements as Site Development Permits – right down to the same FAA clearance for your new one-story home 8 miles from any airport!

This is not to say that the process itself (once you’re a part of it) is in any way simple. We all have experience with different City staff giving different answers and different interpretations for the same issue. And don’t forget all of the ‘optional’, ‘recommended’, ‘case-by-case’ elements – “..if 50% of your site contains slopes greater than 25%, or 10% of slopes greater than 200% with native vegetation and adjoining a street starting with the letters A-F..”. OK, I’m exaggerating for effect, but you get the idea.

In the name of efficiency

The City has decided that in order to create an ‘efficient’ permit process, two things need to happen:

1. The submittal checklist must contain as many items as plausible, to present every staff member the part of the project they need to review, and
2. Drawings and documents for different projects should have as many similar characteristics as possible to improve staff recognition and repetition.

But one person’s efficiency is another person’s nightmare.

The burden on small projects

It’s not surprising where this philosophy has led us. Each project that finds itself with certain ‘qualifiers’ will have to endure the same great deal of requirements. For a larger project with multiple lots or large commercial use, $200,000 in these ‘soft costs’ could be considered simply the cost of development. But for a single residence, $200,000 in soft costs is usually a deal breaker.

What we may need is a little MORE complication

As tempting as it would be to try, the Federal, State, and Local laws of development can’t be simply eliminated. So many rules are simply executions of regulations that cannot be easily changed. But what can be done to allow smaller projects to meet these compliance regulations efficiently and cheaply enough to make them a worthwhile pursuit? Here are a few worthy goals that both public and private industry professionals should pursue:

• Create different ‘versions’ of the same kind of permit. Some cities have their versions of ‘simplified’ or ‘self-certified’ grading permits. These permits require fewer associated reports and/or fewer reviewing departments. But for some cities the qualifications are so specific that projects rarely qualify for one. Good idea, but it still needs improvement, and we need to see it in more instances.
  
• Create abbreviated categories for report documents. OK, so the rules dictate that a biology study and drainage report be prepared for certain project types. Can the City come up with a checklist/questionnaire–style biology study or a short-form drainage report, to be deployed for qualifying single-lot projects?
  
• Allow for up-front participation by decision makers. What if a higher-level manager could evaluate a project at submittal or pre-submittal and allow for efficient shortcuts for small, qualifying projects? Unnecessary or unreasonable submittal items could be waived, and abbreviated report categories could be selected.

These are just a few ideas of some shortcuts within the reach of public officials. How many potential small projects are sitting in the ‘soft cost graveyard’ because they have great promise, but red tape is keeping them from development? These ideas, and more like them, have a chance of making a sizable difference to the burden on smaller projects, and that helps everyone in the industry by bringing more projects back from the dead.

John S. Coffey, PE, is founder and President of Coffey Engineering, Inc. in San Diego. He’s contributed to over a thousand civil engineering, surveying, and planning projects in San Diego and surrounding communities over the past 14 years. 858-831-0111 john@coffeyengineering.com http://www.coffeyengineering.com/