June 11, 2021
Mr. Stephen Adams
Executive Director, UDINS
1718 Argyle Street
Halifax NS, B3J 3N6
Dear Mr. Adams:
Re: New Permit System Concerns
This is further to your June 4th correspondence to Margie Pike, Planning & Development Manager of Business Services, it being the same as your June 7th correspondence to Jacques Dubé, Halifax Regional Municipality’s Chief Administrative Officer, expressing concerns from your members on our new online Permitting, Planning, Licensing & Compliance (PPL&C) system. I understand that these concerns have been discussed during your regular meetings with staff, however, providing them in writing will allow us to provide responses that you can share with your membership. To that end, the following responses are provided in the order the concerns are presented in your correspondence.
- A common issue raised is that the system requires all applications to go through the Development Department for review and sing-off, before it goes to the next, and so forth. Therefore, every time a change is required, it must be addressed by the architect or design consultant before it moves to the next reviewer. The system has also taken away the personal interaction which we desperately need; at least until the issues with this system are addressed.
The new system manages the reviews based on the requirements of the application type. This was a significant business process and workflow change HRM decided to undertake as part of the PPL&C project. The change was to ensure HRM was following best in practice permit workflow. The updated workflow allows any major application issues in building design, site layout, or other zoning matters to be captured and dealt with before any construction related reviews commence. This workflow should not cause delays, but in fact reduce wasted and repeated reviews. We have had some success with these consecutive reviews for our high volume, low complexity files. We’ve been monitoring the activity in the system as the last two weeks to ensure the optimal process will be followed moving forward. We will continue to actively monitor the system.
Further complicating this concern is that some staff members are not familiar with the new system. There is a significant disparity in the level of service received, depending upon who has been assigned the file. These aspects of the new system are not only costly to the applicant, but also add time to the process.
All permitting staff underwent extensive training and continue to participate in refresher support meetings. If a member feels they are not being helped correctly due to lack of skill from an HRM staff member, they should reach out directly to the program area manager. Those contacts are as follows:
Development Approvals – Erin MacIntyre macInte@halifax.ca, or 902-293-7721
Development Engineering – Ashley Blissett firstname.lastname@example.org, or 902-476-7210
Building Inspection – Philip Dugandzic email@example.com, or 902-789-1763
- Many comments focused on the lack of an available staff member to contact to answer questions for any of the steps in the process. It is difficult to ascertain who the individual reviewer is on the file and although they say you can click and find who made the comment, it is impossible. It is unknown if the request for information is delaying the review and because there is no contact person it is difficult to know with whom we should speak.
Within the new system, staff are able to identify themselves once reviews and inspections are completed and comments sent back to customer. If a UDI member is unsure where to locate this information, we can point them to the reference material online or assist via a phone call.
- Contractors are left waiting for weeks at a time for a response to their submission, and if they have questions on amendments required contact information is not necessarily provided. Applicants need to be able to talk to the person in charge of the permit approval.
Staff have been trained to provide their name and contact information with any revision or amendment requests, when providing comments, and when additional information is required of the applicant or contractor. Applicants or Contractors (named on file) can contact 902-490-5650 and leave a message to speak with processing staff at any time. Depending on the review stage, the staff member may be different as permits don’t have one approval group but multiple approvers before the permit becomes Ready for Issue.
Our processing time for permits is reflective of application volume over the spring months. Mid-level complexity files are taking closer to 5 weeks for review or longer if applications are incomplete or multiple revisions are required. Lower complexity files are between 5 – 15 business days currently.
As mentioned above, we recently introduced a push to address any files that have been delayed in having their reviews completed. We will see movement on those files that are from late April and early May over the next few weeks.
- Application dates of when they received the application are not reflective of the actual date the application was made. Whether it is a change of date due to feedback being given to the developer and then their response, it makes it seem as though the application was only made on X date when in fact it has been in the system for multiple months. There are fewer applications in the process than the numbers suggest.
As provided in the industry training and in the online support material, an application is considered Submitted once the online application is completed and fees are paid. A Completeness Check (aka triage, processing) on the application details is done to ensure all information, documents, and fees align and meet Planning & Development and other stakeholder requirements. During this triage, additional information may be requested, fees may require adjustment, or additional permit applications may be needed. Once those requirements are met, a permit application will move to the Review stage. There is no manual interference to dates within the system as it automatically generates and timestamps all activity.
Would you please clarify what ‘numbers’ you are referring to or provide specifics? The new system provides HRM an opportunity to further break down our data and report on stages of the workflow and the time an application has been with the municipality versus with the applicant. We are confident in our data. As of the end of May, HRM had received over 4,300 applications. Below is a table outlining the status of those applications at end of day May 27th:
|Applications In Review||742|
|Applications With Applicant (Additional Information Req &/or Revisions)||534|
|Applications Cancelled or Withdrawn||206|
|Applications Issued, Ready for Issue or Completed||2,835|
- Some very experienced members who have over 50 successful applications for industrial/commercial warehouses are struggling with the process and timelines. A permit application which usually took four weeks has now taken over 8 weeks, with no end in sight.
Please see our response above to item 4. regarding processing times.
- The new online system has been described as very clunky. It is hard to find permits that you have applied for and track what it what. When a builder has a high volume of permits, they all cannot be seen on one page. A search is required for all building permits which is very time consuming, as you cannot go back to the previous page. You are required to go out and start the search again. If there is a way in which to delete obsolete permits, we would appreciate information as to how to do it.
- A consultant with 20+ years of experience is going to hire someone to deal solely with permit applications, as his staff is overwhelmed by the new system. And a builder has had to dedicate someone for 5 days a week to focus on permits. Under the former system, 3 days were required.
Customers with high volumes of applications have experienced high levels of success by virtue of practice and familiarity with the system. As we reviewed during industry training and refresher discussions for over 250 industry members, there are multiple ways for an applicant to view what activity is happening on their Customer Portal. All active applications can be viewed on one page.
There is an abundance of educational material online and we continue to provide one on one help for any industry members requiring assistance. This assistance can be as simple as how to filter, view and search. We can also provide a training session to those UDI members who were not able to join us at previous sessions.
- It does not seem that there is enough staff (at least Engineering and Development) to review things in a timely manner. To further complicate this, when a resubmission is made to address engineering comments towards a subdivision, we continually get additional comments that were not made on previous submissions. In a few instances, our members have been told, “due to excessive applications no one has been assigned to the file”, even when it is complete.
We have experienced a larger than expected volume of applications for subdivisions over the last few months. Subdivision work is completed outside of the PPL&C system in our previous software and in order of submission.
I understand that you have spoken with staff about changes that will be implemented to the review process when new Engineering Guidelines are approved by Council. Staff understand you to be supportive of these changes to the engineering review process of subdivisions. Council recently approved additional staff resourcing so this, combined with these review process changes, should result in reduced processing times for subdivision applications.
The implementation of the new PPL&C system means changes to how staff and our partners do business. It means less time that applicants must visit an office, less paperwork, less unnecessary reviews, and less in-person interaction in filing applications, all of which were concerns previously voiced by industry relative to the inadequacies of our historic permitting system and processes. The new system brings with it a host of new abilities for our customers: 24/7 access, ePayment, Contractor Profile with employee access, shared access to permit details, digital inspection requests and inspection results between applicant and associated contractors. None of these functions were available to our customers six months ago.
How long it takes customers to adapt to the new system will vary depending on how frequently they use the system. As user proficiency grows, so will the user experience. A technology implementation and change of this size and scope can take a significant amount of time for the majority of its benefits to be realized. We ask for your support and patience as we continue to work with the new system and leverage its advantages.
As we have previously communicated, Planning & Development continues to offer in-person service and virtual meetings by appointment to help those applicants who require more hands-on assistance. Customers are welcome to request this services at any time by contacting us at PPLC-Info@halifax.ca .
Thank you again for providing us with this feedback and we look forward to our continued collaboration with UDI.
Planning & Development
Halifax Regional Municipality