May 23, 2002

Harvey M. Rose
Budget Analyst
Board of Supervisors
1390 Market Street, Suite 1025
San Francisco, CA 94102

Re: Planning Department Response to 2002 Draft Management Audit Report

Dear Mr. Rose:

Attached you will find our detailed response to your office"s Draft Management Audit of the Planning Department. The response is broken down by section. Generally, it is divided into suggested corrections of inaccuracies that we identified in the report and includes clarifications and comments about the feasibility of implementing some of the recommendations. The only recommendations that were specifically addressed were those made to the Director of the Department.

As we stated in the initial response of April 12, we feel that the Budget Analyst"s report contains much useful information and constructive recommendations which will be helpful in improving both the Planning Department and the Planning Commission"s performances.

It has always been our commitment to get the response to you with sufficient time for review by the members of the Board of Supervisors and certainly well in advance of any public hearings on the audit.

In conclusion, we look forward to working with the Budget Analyst, Planning Commission, the Board of Supervisors, and Mayor in implementing appropriate improvements. We also look forward to responding to the Budget Analyst"s Audit Report in future hearings before the Board of Supervisors.

Sincerely,
Gerald G. Green
Director of Planning

GGG:gcb
Attachment

Planning Department
Response to the 2002 Draft Management
Audit Report
May 23, 2002
Gerald G. Green
Director

Section 1: Commission Compliance With State And Local Mandates

Accuracy Comments

Page 1-4: The Budget Analyst"s Report opines that - " (The) adoption of City legislation can best occur through multi-year strategic planning process."

A multi-year strategic planning process might not be flexible enough to address the changing priorities of the Board of Supervisors. It"s unclear how such a multi-year strategic planning process would have addressed the changed priorities of last year"s new Board of Supervisors who were elected through district elections. The Department encourages the Board of Supervisors to hold regular hearings to articulate their planning priorities.

Page 1-6: The report states that the Director changes the Work Program during the year to reflect unforeseen circumstances and changes in funding. It also concludes that the Director without an overriding set of goals, objectives and priorities makes reallocation decisions for the year formally established by the CPC with input from the Board of Supervisors.

The work program is initially adopted by identifying strategic Department planning objectives and in response to the stated planning priorities of the Board of Supervisors. A "reconciliation report" is presented mid-year to the Planning Commission for any major changes to the Department"s work program. The Department feels strongly that a similar process needs to be implemented at the Board of Supervisors, whereby the Department would come before a Committee of the Board to present suggested changes to the work program as a result of reductions in the Department"s revenue. In addition, the Department"s Liaison to the Board of Supervisors currently fills the crucial role of meeting with Supervisors and their aides on a regular basis to ascertain individual members" planning priorities.

Page 1-11: "a number of departments reported that they are not kept informed or asked to participate in Planning department projects [such as the Better Neighborhoods Program] that will or could have an impact on their areas of jurisdiction".

Specifically on page 1-12:

The Public Utilities Commission (PUC) claims to have had "no forewarning of a proposal by the Planning Department to build housing on the Balboa Reservoir, over which the PUC has jurisdiction".

This is simply not the case. Planning Department staff invited PUC staff to the workshops where the idea was discussed. PUC staff declined to attend (documentation can be provided). More importantly, this was not a proposal. The Planning Department is not moving forward with any proposals for housing on the reservoir. Numerous ideas were talked about at these meetings -- the nature of community-based planning is to get as many ideas out there as possible. The next step in our on-going community planning effort is to make public draft plans for review by the public and other agencies, after which proposals may be made as part of the final plan.

The San Francisco Redevelopment Agency (SFRA) claims to have "not been asked to provide input into the Market and Octavia Better Neighborhood effort...."

This is an incorrect statement. Not only has the SFRA been invited to participate, several staff members have been actively involved in the process from the very beginning, and have even served as facilitators in our workshops. (Documentation can be provided). The Planning Department has played the lead role in facilitating the public process and in developing design guidelines pursuant to the disposition of the Central Freeway Parcels. This has been on-going for one and a half years. (Documentation can be provided).

The San Francisco County Transportation Authority (SFCTA) claims to have "had no forewarning of a Planning Dept. proposal to ban vehicles on South Van Ness Avenue even though such an action would have a significant impact on transportation projects..."

Again, closing South Van Ness Avenue to through traffic was not a proposal. It was a working concept, like many others, evolving from a MUNI proposal for a dedicated bus lane that was presented for the public"s consideration at a community workshop. An important part of community-based planning is getting as many ideas out there as possible, and inviting other agencies as well as the public to engage in a debate as to their merits.

It"s worth noting that while the SFCTA was invited to the meeting where this was presented and the SFCTA"s director attended, he stayed only long enough to hear the concept mentioned and left before the public discussion, at which point his concerns would have added greatly to the discussion. Both the public in attendance and MUNI staff were intrigued by the concept. Prior to the current director"s appointment, Planning Department staff worked extensively with Andy Nash on the design of the new central freeway touchdown at Market Street. SFCTA staff continues to be invited to community workshops and are in close communication concerning several transportation ideas coming out of the Balboa Park Better Neighborhoods 2002 (BN) plan. (Documentation can be provided).

The long-range planning function of the Planning Department is in the position of trying to balance the competing interests and perspectives of more than a dozen other agencies. These agencies are, by and large, focused on the detailed management of a single city function. The role of long-range planning, in contrast, is to provide a broader context, a larger vision that integrates these various functions. While we would not propose specific designs for a piece of transportation infrastructure, for instance, it is our role to promote the transportation goals outlined in the General Plan. In terms of community planning, this often means bringing to the public debate ideas that stray far from conventional practice in other city agencies.

The public has, all things considered, come out in support of the more "controversial" working concepts in the BN planning effort. The resistance these ideas face comes primarily from other agencies, where they go against standard practice. Facilitating the public debate of these issues is central to the community planning process. Ultimately, the success or failure of each idea will depend on public support of these ideas after an open discussion of their merits with all city agencies, including the Planning Department. The role of the BN process is to get the ideas out there and to start the debate.

As an example, we have suggested that in the case of Van Ness Avenue north of Market Street, 2 of the 6 existing traffic lanes should be dedicated exclusively to transit and the sidewalks redesigned to improve pedestrian safety, facilitating the more efficient movement of people and in keeping with the City"s Transit First policy. We feel that it is of the greatest importance that this idea saw the light of day in a public workshop, where the public actively discussed it. Had the approval of more than a dozen agencies been required prior to the discussion, it is unlikely that it would ever have seen the light of day.

Page 1-12: The Audit refers to "the Planning Department"s MOU with the Redevelopment Agency". The document is actually entitled a Master Services Agreement (MOA).

Recommendations

1.1 The Planning Commission should prepare a long range strategic plan integrating a broad set of short and long term goals, objectives and action plans for the Commission and the Planning Department, including timetables and specific measurements of plan accomplishment.

The Department agrees with this recommendation. However, a long-range strategic plan is dependent on long-range fiscal support, which is impacted by ever changing economic climates and a short-term budget process. It is unclear how such a multi-year strategic planning process would have addressed the changed priorities of last year"s new Board of Supervisors who were elected through district elections. As previously stated, the Department encourages the Board of Supervisors to hold regular hearings to articulate their planning priorities.

1.2 The Planning Commission should establish an annual process for formally receiving input from the Board of Supervisors and the public regarding goals and objectives for the planning function and incorporate them into the establishment and annual updates to the strategic plan.

The Department agrees with the recommendation. The Clerk of the Board of Supervisors should perhaps initiate the process of formally transmitting planning related decisions to the Planning Commission.

1.3 The Planning Commission should develop a process for annually evaluating accomplishment of the strategic plan including measurements of actual performance and timetables of projects and activities included in the plan.

See 1.1 above.

1.4 The Planning Commission should require the Planning Director to structure the Department"s annual Work Program to present the link between planned activities and strategic plan goals and objectives.

The Department agrees. This is already being carried out, and the Department intends to continue the process.

1.5 The Planning Commission should require the Planning Director to provide a detailed reconciliation between the annual Work Program and the budget each year after the annual budget is adopted and to provide this to the Commission and the Board of Supervisors.

The Department agrees. The work program is initially adopted by identifying strategic Department planning objectives and in response to the stated planning priorities of the Board of Supervisors. A "reconciliation report" is now presented mid-year to the Planning Commission for any major changes to our work program. As stated above, we feel strongly that a similar process needs to be implemented at the Board of Supervisors, whereby the Planning Department would present suggested changes to the work program as a result of reductions in the Department"s revenue.

1.6 The Planning Commission should establish coordination and cooperation with other City agencies as a performance measurement for the Planning Director and measure actual results in this area through an annual survey of other agencies involved in planning and land use, to be presented to the Commission,

The Department will always support measures to improve coordination between other city agencies. However, why hold the Planning Director responsible when the opinions expressed in an annual survey (of other agencies) is affected by circumstances outside the performance of the Director. As an example, the Audit concludes that the Department is not using the Travel Demand Model development by SFCTA. The Department is using the SFCTA model. However, where it has been used, some additional work has been required to get to a level of service analysis (at intersections) that is required for an EIR. In order to determine the level of service at various intersections in a complex street grid, transportation consultants have had to manually assign traffic to the street system, rather than rely entirely upon the output from the model. The Master Services Agreement with the Redevelopment Agency was dependent upon staffing which was not funded in the FY 2001/2002 budget.

1.7 The Planning Director should revise the Planning Department"s budget structure to present the budgets for each of the Department"s five divisions.

The Department agrees. Currently, the cost and revenue figures for four of the five divisions are presented in the Work Program and in the Department"s Budget. The costs of the Department"s fifth division, Administration, are spread throughout the other divisions. Those administrative costs could be separated for next year"s fiscal year budget.

Section 2: Planning Commission Discretion

Accuracy Comments

Page 2-3: "A review of a sample of development projects that require Conditional Use approval conducted as part of this management audit found potential or actual problems, resulting in lack of compliance with the Planning Code..."

The Audit Report does not cite examples so the Department is unable to verify the accuracy of this statement.

Page 2-3: Large scale development of such (Live/work) projects ... overall did not conform with the General Plan

The Budget Analyst states an opinion when he claims that the approval of 1,500 L/W units violated General Plan priority policies. In making its decisions, the Commission made appropriate General Plan findings.

Page 2-5: "In Case 00-1195 ... if the Planning Code did not allow exceptions to the ground level public services requirement in office buildings, the Planning Commission would not have had the discretion to approve office buildings without such services, and the First and Howard Streets area would have office buildings with ground level public services."

This statement is inaccurate. The 1st and Howard project was approved with ground floor services and restaurants. 199 Fremont has ground floor retail and restaurants. However, 547 Howard was on a 25" wide lot and only 85" deep, and did not lend itself to ground floor retail. Its entry lobby and circulation would have only left a minimal retail presence. This block of Howard also does not have a strong retail presence, and this site would have been difficult to lease successfully.

Page 2-5: Approval of a housing project exceeding the 40" height limit permitted in the Planning Code.

The Budget Analyst does not understand the history of the 40" Conditional Use requirement. The public expressed deep concern about allowing buildings of over 40 feet in height in a residential district without public review before the Planning Commission. We do not understand what is meant by the statement, "However, because the project sponsor was required to obtain Conditional Use approval, despite complying with the Residential Design Guidelines and the Van Ness Avenue Plan, because the Planning Code does not set further height limits for development in this zoning district, the Planning Commission had the discretion to approve or disapprove the project." First, the Residential Design Guidelines are not applicable in this district, since it is both a Residential-Commercial District and has a height limit of over 40 feet in height. Furthermore, a primary purpose of bringing any case to the Commission is for the Commission to use its discretion after hearing from the public. If there was no need for public input or discretion, the application could have been approved administratively.

Page 2-7: Discretionary Review (DR)

The Planning Commission disapproved or modified 62 percent of cases in 2001. The Budget Analyst believes that the high number of cases demonstrates that the Planning Code does not work, but he ignores that we now require separate DRs from each applicant, and the Planning Commission and the Board of Supervisors both have implemented mandatory Discretionary Review policies, thus increasing the number of DRs.

Page 2-9: The Audit Report inaccurately states that: "The Planning Department"s Better Neighborhoods Program, which will add new neighborhood plans to the Planning Code, will note allow Conditional Use approval for projects in the neighborhood."

The Department has neither made that determination nor proposed to do so. An overall theme of this section is that the Budget Analyst seeks to eliminate discretion by the Commission and the Department. This is contrary to public policy, fails to take into account the complexities of land use in San Francisco, and it seems to be contrary to the Board of Supervisors" current policy to increase Conditional Uses and Discretionary Reviews.

Recommendations

"We recommend that the Director of the Department of Planning:"

2.1 Review the Planning Code to determine instances where application of Conditional Use could result in failure to conform (to) the General Plan or comply with the intentions of the Planning Code.

The Department disagrees. This is a confusing recommendation and demonstrates a lack of understanding of what a conditional use request is and what the relationship is between a conditional use application and the General Plan. There"s no need to modify the Planning Code because prior to approval (or denial), compliance with the General Plan must be established and stated.

2.2 Assign a long range and current planning staff to work with community planning committees to identify and propose Planning Code changes, that set firmer zoning requirements for projects within specific zoning districts.

The Department believes that this could be implemented if clear objectives are set and if additional funding and staffing are provided. This can also be implemented through the Better Neighborhoods Program.

2.3 Present a proposal, including goals, timelines, and measurable results, to the Board of Supervisors during the FY 2002-2003 budget process for the review of the Planning Code application of Conditional Use.

The Department disagrees with this recommendation. Please see 2.1 above.

Section 3: Industrial Protection Zones, Live/Work Projects And Community Plans

Accuracy Comments

Page 3-10: The Budget Analyst"s audit inaccurately states that the Planning Code does not define Arts Activities.

Planning Code Section 102.2 does clearly define Arts Activities.

Recommendations

"The Director of the Department of Planning should:"

3.1 Submit amendments to the approved annual Work Program and budget in writing to the Board of Supervisors, as well as the Planning Commission, with an explanation of the Department"s reasons for selecting reductions to each program.

The Department agrees. Please see the response to recommendation 1.5.

3.2 Develop a stricter definition of "live/work", including defining live/work projects as housing and the zones in which live/work are permitted, and recommend Planning Code revisions to the Planning Commission.

The Department agrees. This could be done as part of the Community Planning Process currently in progress in San Francisco"s five Eastern Neighborhoods.

3.3 Rigorously identify which projects are permitted or not permitted and limit the types of projects subject to conditional use in developing the community plans and the permanent zoning controls and recommend Planning Code revisions to the Planning Commission.

The Department agrees.

3.4 Develop a formal tool for assessing and incorporating community input in the community plans.

The Department agrees, as this is one of the primary goals of the Better Neighborhoods Program as well as the Community Planning Processes in the Eastern Neighborhoods.

Section 4: Community Participation

Recommendation

"The Board of Supervisors should:"

4.1 Establish advisory community planning committees in each Supervisor"s district and appoint representatives to the community planning committee within the district.

4.2 Consider establishing a steering committee, comprised of one representative from each of the community planning committees, and an advisory interest committee, comprised of members of professional architecture and planning associations, building and land use groups, environmentalists, and other stakeholders in the planning process.

The Planning Department always welcomes community input into the planning process. We do, however, have a concern about the role of such committees and their relation to already established neighborhood groups that are currently active in the planning process. In addition, a newly formed Planning Commission with appointments by both the Mayor and the Board of Supervisors is due to take effect on July 1 of this year.

"The Planning Commission should:"

4.3 Establish regular planning policy workshops to provide an opportunity for Commissioners and community members to participate in a more general discussion about planning issues.

As stated above, the Planning Department welcomes maximum community input into the Planning process. The Department"s community planning process in the Eastern Neighborhoods has included public workshops in the neighborhoods where general planning issues were discussed. In addition, general planning items are regularly scheduled at the Planning Commission, such as the recent discussion on the Commission"s residential demolition policy.

"The Planning Department should:"

4.4 The Planning Department should develop work plans that incorporate the community planning committees in developing General Plan and Planning Code proposals.

The Department agrees.

Section 5: Long-Range Planning Program Management

Recommendations

"We recommend that the Director of the Department of Planning:"

5.1 Identify and maintain sufficient resources to achieve its long range planning goals and present changes in the Citywide Policy and Analysis work program to the Planning Commission for public review and discussion:

5.2 Develop well-formulated realistic work plans for long range planning projects and rigorously monitor work plan timelines:

5.3 Work with the Planning Commission to request the completion and to schedule public hearings of draft long range planning policies before the Commission.

5.3 Direct the Chief of the Citywide Policy and Analysis Unit to present monthly status reports to the Director of Planning on all projects, including all hours spent compared to the number planned, milestones accomplished, and explanations for any delays.

5.4 Direct the Chief of the Citywide Policy and Analysis Unit to present monthly status reports to the Director of Planning on all projects, including all hours spent compared to the number planned, milestones accomplished, and explanations for any delays.

In the context of the funding and staffing issues described in this section, we generally agree with the above recommendations. The preparation of rigorous and detailed work programs is futile, however, without the resources to follow through. Where funding and staffing have been in place, we believe that work programs have been developed. When funding and priorities have been consistent, we believe that they have been carried out. More rigorous monitoring and reporting can increase intelligent oversight where resources are sufficient.

Section 6: Permit Streamlining Act

Accuracy Comments

The Audit Report concludes from statistics that the Department is not complying with State law governing processing time. The numbers don"t lie in terms of processing time. The report, however, does not recognize that the reality of the development process in San Francisco is the inclusion of community input, neighborhood meetings, and project alterations. This dialogue and community-based approach add time. This reality is not discussed and is not accounted for in the State law.

Regarding the Environmental Review processing time, based upon a sample of Negative Declaration cases, the Audit Report found that the Department took an average of 211 days to complete the Negative Declarations, rather than 180 days as required by the Permit Streamlining Act. The Analysis in the Audit Report is flawed at several levels. The analysis did not subtract out the minimum of 30 days per application for applications to be reviewed before they are accepted as complete. In many cases, additional information is required of an applicant before an application is accepted as complete. Subtracting out that minimum 30 days alone would have reduced the average time period to 181 days. In fact, in many cases, more than 30 days would be subtracted out due to specific requests for additional information and studies before the application would be accepted as complete. In addition, the permit streamlining "clock" does not begin to run until 30 days after the filing of the environmental evaluation application, or the permit approval application, whichever is later. If the permit approval application for any of the sample of cases were filed after the environmental evaluation application, the average time period would likely be reduced to less than 180 days. Similarly, the permit streamlining "clock" is stopped when the processing of the case is delayed as a result of a project sponsor"s actions. This is often the case for many projects, where the project is revised after the initial application, or where additional information is required from the project sponsor. Subtracting out time, as appropriate, for all of the reasons above, would have brought the average time for the sample of cases to well under 180 days.

Nevertheless, the Audit Report is correct in terms of its assessment and recommendations that the Department could improve on its mechanisms to inform the public, and track and report upon the key dates and information relevant to the Permit Streamlining Act.

Recommendations

"It is recommended that Planning Department management:"

6.1 Clarify the process and instruct staff on what qualifies for determining application completeness and the need to comply with the state mandated 30-day time limit on this process.

The Department agrees. This function is already being carried out. Please see 6.5 below.

6.2 Revise all Department application forms, printed materials and web site to include detailed lists of all information and materials that will be required of applicants, including items that are not mandatory but commonly required for project types most frequently reviewed by the Department.

The Department agrees.

6.3 Revise all Department application forms, printed materials and web site to state that all applications will be reviewed and their completeness determined within 30 days of submission and to disclose the criteria by which completeness will be determined.

The Department agrees.

6.4 Revise all Department application forms, printed materials and web site to include disclosure of all Permit Streamlining Act and California Environmental Quality Act (CEQA) time limits.

The Department agrees.

6.5 Instruct all staff on time limits and importance of compliance

The Department agrees. This is already being carried out. In March 2002, staff received a briefing/presentation from a representative of the City Attorney"s office on the law, and the legal responsibility to comply with time limits. The department intends to repeat this annually.

6.6 Add necessary data collection ability to the Parcel Information Data Base to capture all key milestone dates needed for compliance with State case processing time limits, including date application submitted, date application determined complete/incomplete, date Initial Study of environmental impacts completed, date of environmental review action, and date of final action on application.

The Department agrees. However, adding new data collection ability to the Parcel Information Data Base will require network system infrastructure or software changes that must be funded.

6.7 Add necessary data collection ability to the Parcel Information Data Base to capture other key dates in the process to identify backlogs such as date of case assignment to a planner, date work commencement, and others.

The Department agrees. Please see the response to 6.6 above.

6.8 Collaborate with the Department of Building Inspection regarding adding fields to also collect key milestone dates on the Permit Tracking System to track Permit Streamlining Act compliance.

The Department agrees; please see the response to 6.6 above.

6.9 Assign responsibility for accurate and complete data entry by their staffs to all Department neighborhood Planning managers.

The Department agrees.

6.10 Begin production of a regular monthly report for the Director showing compliance with Permit Streamlining Act and CEQA requirements, case backlogs and other relevant information to enable management to expedite permit processing to the extent possible.

The Department agrees. However, rather than monthly, this should be included in an annual report.

Section 7: Planning Staff Turnovers And Vacancies

Accuracy Comments

The Department had provided a detailed listing of internal promotions within the Department from the period of January 2000 through present. A summary showed that in 2000 there were 23 internal promotions and in 2001 there were 22 internal promotions. Given that the Department has approximately 100 technical planners, the promotional record is at 22%-23% per year for at least the past two years. This track record of promotions allows for approximately 1 in every four planners a promotion each year. The Planning Department rate of promotions is high in comparison to other City departments. The Department offers the Planner I thru Planner V classifications. This offers a defined line of promotion for planners. (See attached.)

Recommendations

Recommendation that the Director of the Department of Planning:

7.1 Require Department managers to conduct annual performance evaluations for all staff Planners to increase the level of communication between management and staff and to provide feedback to staff on job performance

The Department agrees. To implement equally and fairly, however, all supervising staff will have to be trained in the methodology of doing evaluations and use the same system of evaluations consistently and uniformly throughout the Department. In the past, two separate "official" systems have been used. The Performance Appraisal Report rates employees in one of five levels of performance factors and managerial factors. This requires the use of a standard form. Another system was introduced in the late 1990s called the Performance Management and Appraisal system, which is not used universally. Using this system, the employee and supervisor jointly develop a job description and job standards and conduct performance conferences throughout the year so that an employee work plan can be developed that is evaluated at the end of a one year period. This system requires more employee input in creating a job description and setting goals and measurement standards.

No matter what, to implement this recommendation will impact the amount of time managers spend on staff development and upgrade. It is a valuable process, however, and the ultimate cost will be on time management, review of project work and on policy development.

7.2 Conduct annual morale surveys to identify workload problems, communication failures between staff and Department management or the Planning Commission, and other factors contributing to poor staff morale. The results or the morale survey should be presented to the Planning Commission and used as a factor in an annual evaluation of the performance of the Department Director.

The Department agrees that the Director should be held accountable. There is, however, a concern about publicizing personnel issues over which the Commission has no authority.

7.3 Establish a voluntary work rotation system, providing Planners the opportunity to work in all areas of the Department; and consider voluntary rotation to each of the organization"s units as one factor in promotions.

The Department disagrees. This has not worked in the past and could result in an uneven allocation of staffing.

7.4 Increase work opportunities for staff Planners by assigning Neighborhood Planning staff to special projects other than application processing and establishing teams from Citywide Policy and Analysis and Neighborhood Planning to work on specific issue or geographic related tasks.

The Department agrees. This is already being carried out through assignments and through joint meetings on Urban Design and Policy issues.

7.5 Improve communication between staff and senior management, by delegating more decision making responsibilities to Planner V staff, regularly attending division staff meetings or calling regular Department-wide staff meetings, increasing Zoning Administrator drop-in hours, and setting up communication channels, such as regular email access.

The Department agrees. This is already being carried out and is a regularly expected process at the Department.

7.6 Assist new and inexperienced staff in Neighborhood Planning by assigning mentors to junior staff and increasing team leader participation in project reviews.

The Department agrees. This will, however, have an impact on time processing of project applications and will put more pressure on time management.

7.7 Adopt and implement the Department"s draft policy for reduced work schedules and draft a telecommuting policy

While the Department agrees that this is a potential morale booster and a way to retain valuable staff, this recommendation needs much further exploration and development. Issues that need to be addressed are time processing, liability issues of working at home, and staff availability (or lack of) to the public.

Section 8: Efficiency And Effectiveness Of Public Information Center

Accuracy Comments

Page 8-1: The report inaccurately lists the number of FTEs covered by the funding for PIC as 7.5. It is actually 9.75.

Recommendations

"It is recommended that the Planning Department Director:"

8.1 Accelerate the physical improvements to the PIC that expand the service area, revise the signage, eliminate the 15-minute time limit on staff services (sign), install improved seating, and move telephones.

The Department agrees. This will, however, require assistance from the Department of Building Inspection (who shares first floor space) and will necessitate sufficient funding. As to the 15-minute policy, it is intended to allow all people to be served in a timely manner. If it takes more than 15 minutes to process, it is likely that more attention is needed to the issue at hand than is appropriate at the counter.

8.2 To ensure that useful and accurate data are collected, a greatly modified tally sheet content and process should be employed as follows: (Please consult Draft Audit Report for the lengthy details of this recommendation).

The Department disagrees. We are not sure what is the purpose or benefit of this recommendation.

8.3 Emphasize the importance of PIC training for staff and see that service data are used to develop targeted instruction:

The Department agrees. This is already being carried out at the PIC management meetings and at training sessions.

8.4 Encourage reservations for persons wishing to access planning services at the PIC.

The Department agrees. People can already make appointments with appropriate staff persons and some appointments can be arranged with counter personnel as well.

8.5 Consider reviving the internal Planning Code Simplification Project to determine what resources are needed for its completion and then schedule if practicable.

While simplification of the Planning Code is extremely worthwhile, this is a complicated issue. It requires additional personnel and/or funding, and we do not believe that this is the appropriate section to address this subject.

8.6 Update, then implement a streamlined policy and procedures manual for the PIC including discussion of basic customer service and the importance of communicating to customers that help will be forthcoming when there are backlogs at the Counter.

The Department agrees. Customer service and good communication are already discussed in training sessions.

8.7 Develop an assignment and rotation system that ensures balanced staffing for the PIC from all organizational units and enables employees who have expressed a preference for the PIC to be assigned beyond their scheduled shifts.

The Department agrees. This is already being carried out.

8.8 With assistance from the Department"s Chief Financial Officer, prepare and implement written procedures for handling cash at the PIC.

The Department agrees. It is to be noted, however, that no large sums of cash are ever stored at the PIC.

8.9 Designate a set number of hours per week for assigned staff to work exclusively on updating all handout materials.

The Department agrees. This is already being carried out.

Section 9: Organization And Management Structure

Accuracy Comments

Page 9-2, Exhibit 9-1 Comparison of Manager Salaries, Positions, Reporting and Functions, Planning Department, should be corrected as shown below.

Exhibit 9-1

As shown in Exhibit 9.1, the median number of reporting positions for all managers, excluding the Zoning Administrator, is 20.5. For Planner V"s only, the average is 20. Within the Planner V group, the range around the median number of reporting positions of 20 is 11 through 27...The Operations Manager and the Manager of Finance and Administration have 7 and 9 positions reporting, respectively.

Page 9-5: Exhibit is incorrectly labeled 5.2. It should be 9.2 and should be corrected as shown below.

Exhibit 9.2

Recommendations

"It is recommended that the Board of Supervisors:"

9.1 Delete one Planner V position fro the Department"s budget when attrition allows:

9.2 Delete three Planner IV positions from the Department"s budget when attrition allows:

"It is recommended that the Planning Director should:"

9.3 Restructure the organization by transferring the administrative functions now under the Planning Commission Secretary and the Information Services division now under Planner V to the Manager of Finance and Administration.

9.4 Transfer responsibility for the Planning Information Center to the Zoning Administrator as manager of the Neighborhood Planning unit.

The Department disagrees with the above recommendations. The conclusion that Administrative functions such as IS (Information Services) and operations be consolidated under one manager is based solely on headcount. The current headcount reporting to the manager of Finance and Administration is nine. There are three functional areas with a staff of three in each. In the Planning technical areas where there is a Planner V in each Division with 21 staff members, there is only one functional area, i.e., MEA, Neighborhood Planning (Quadrants), and Citywide. The headcount criteria of analysis are not viable due to the varied skills, knowledge, and experience required to manage the various functional areas in administration.

Finance - Knowledge of governmental accepted accounting principles; budget and financial analysis; fee collections; interpretation of planning code for fee revenue, and exactions; interfacing with the Mayor"s Budget Office and the Controller"s office.

Personnel - Knowledge of Civil Service Rules and Regulations; understanding of Local MOUs; knowledge of payroll policy and procedures for processing; knowledge of latest state laws and fair employment practices; interface with the Civil Service Commission, DHR, the Controller"s Payroll Division, and the City Attorney.

Contract Administrations - Knowledge of and compliance with the Minority, Women and Small Business selection processes of the Human Rights Commission; knowledge of the Administrative Code, the State Contracting Codes, and the Purchasing Codes. Interface with the Human Rights Commission, Civil Service Commission, City Attorney, and the Chief Administrator and the Purchaser.

It is clear that the management of Administration requires knowledge in various disciplines and cannot be compared to the technical planning functions that have been separated into divisions within the Planning Department. The headcount approach to reorganization for administration does not take into consideration the processes, procedures, mandates and approvals required to operate each functional area of Administration.

Section 10: Department Fees And Cost Recovery

Recommendations

"It is recommended that the Director of the Department of Planning:"

10.4 Immediately design and implement a method for insuring (sic) accurate capture of staff time expended on planning services within the Department"s different organizational units:

The Department currently uses software to track individual planners" times. The Time Accounting System currently keeps track of individual planners" times by project.

10.5 Accelerate implementation of the Controller"s recommendations pertaining to Special Fees. However, carefully review the Treasurer"s current proposal for centralized collection of all fees to ensure that the Department cooperates with the appropriate departments in implementing the process determined to be in the City"s best interest.

The Department agrees. This is already carried out through the responsibility of an Administrative Assistant 1823 position that was added to the Department"s FY 2001-2002 budget. We also support existing legislation to have the City Treasurer collect fees, provided that the Administrative Assistant position remains in the Department"s budget.

10.6 Determine if there are projects not included in the Controller"s sample of 32 projects that are subject to special fees and any amounts paid and due, e.g., projects smaller than 25,000 square feet in size as well as all hotel and residential development.

The Department agrees.

10.7 Enter details of all approved special fees in the Parcel Information Database at the time of project approval.

The Department agrees.

10.8 Prepare an annual Special Fees Information Report and submit it to the Planning Commission, including a comparison with the total square footage of all approved project types in the same period.

The Department agrees. This should be a part of an annual report.

10.9 Ensure that the Parcel Information Database includes appropriate fields for fees that correspond to the fee-related fields in DBI"s Permit Tracking System:

The Department agrees. Please see our response to recommendation 6.6 for further clarification.

10.10 Develop and install a quality assurance/quality control procedure to ensure that all data entries are timely and accurately made, and with the appropriate and clearly auditable managerial approval.

The Department agrees.

10.11 Obtain input from the Controller and City Attorney and report back to the Planning Commission regarding the feasibility of placing a portion of fee revenues in a reserve fund for pre-approved, future costs such as technology system upgrades.

The Department agrees with this recommendation. In fact, this idea has already been actively discussed at the Department.

Section 11: Evaluate Department"s Current And Planned Information Technology

It is recommended that the Director of Planning:

11.1 Continue with strong commitment to the information technology function and ensure an appropriate level of dedicated financial support based on an updated Five-Year Plan: (Please consult Draft Audit Report for details of the Plan.)

The Department agrees. It should be noted, however, that the Director"s ability to ensure an appropriate level of dedicated financial support for an updated 5-year plan is extremely restricted and should be addressed by the Board of Supervisors through the Budget process. The Department"s network system is currently dysfunctional and is inoperable on many days. This is directly linked to inadequate funding in the first two years of the 5-year plan.

11.2 Develop a timetable to accelerate the completion of all system documentation.

The Department agrees with the concept. We need, however, a more clear definition of the Budget Analyst"s definition of "system documentation."

11.3 Prepare simplified user guides for staff and users of the Public PC.

The Department agrees.

11.4 Work with the Department of Building Inspection to ensure that compatibility of software versions and all issues of security are resolved so that interface with the Permit Tracking System is implemented before the end of this fiscal year.

The Department agrees. This is already being carried out.

11.5 Develop and install appropriate management and quality controls of Department applications to minimize erroneous content as well as system misuse and abuse.

The Department agrees.

11.6Implement a schedule of training classes necessary to ensure the appropriate information technology proficiency for all levels of staff, including planners, support staff and IT staff.

The Department agrees. This is already being carried out on a limited basis.

11.7 Implement an annual staff customer satisfaction survey for the Information Services function and incorporate the results in the annual performance evaluation of the I.S. Manager.

The Department agrees.

Section 12: Training

Recommendations

"It is recommended that the Director of the Department of City Planning:"

12.1 Ensure that all classifications of employees are regularly made aware of the resources available and the procedures required to access them for participation in the full range of training and development activities related to the various functional specializations of the Department.

The Department agrees. This is the current practice in the Neighborhood Planning division. Information on training classes is regularly disseminated via weekly Department-wide e-mails.

12.2 Update the Department"s policies and procedures as necessary to reflect and facilitate access to training and development resources.

The Department agrees. This is current practice, as the one trainer in Neighborhood Planning is continually updating policies and procedures based on feed back from end users.

12.3 Establish a policy clearly stipulating that all donations from the Friends of San Francisco City Planning must be of a nature and for products and services that benefit the Department as a whole and not just individuals.

12.4 Create the corresponding procedures to implement the policy in 12.3.

In response to recommendations 12.3 and 12.4, the Department requests various grants from the Board of Directors of the Friends of City Planning for unbudgeted work-related staff training and development, and computer software and/or equipment for the Department as a whole. The grant funds are not for individuals.

12.5 The Department should periodically review problem areas in the provision of technical services to determine where administrative or procedural modifications seem warranted as well as cost effective and possibly more appropriate than training solutions.

The Department agrees with this recommendation in those instances where it is cost effective to make administrative or procedural changes instead of training solutions.

12.6 Examine ways in which effective functional integration and cross training can be achieved among the Department"s major Divisions and implement a program to accomplish this.

The Department agrees with this recommendation to set up a pilot program for cross training among the Department"s major Divisions.

12.7 In the light of work process changes resulting from emerging technologies, evaluate the overall support staff function and determine how, if necessary, it might be restructured to ensure optimum utilization and effectiveness in the different divisions.

The Department agrees.

12.8 Monitor the Department"s training and staff development activities and report on them to the Planning Commission annually.

The Department agrees with the recommendation to monitor the training function and report to the Commission. This should be a part of the Department"s Annual Report.

Section 13: Enforcement

The audit report captures the main problem with this division very accurately by stating that: "the Enforcement Unit of the Planning Department is insufficiently resourced to effectively manage the Planning Code enforcement workloads...." The audit goes on to say: "We estimate that the Enforcement Unit would need an additional four planners and additional vehicles for at least a two-year period in order to achieve control of its existing workloads and new accessions."

Recommendations

"We recommend that the Director of Planning:"

13.1 Request limited additional resources to adequately staff and equip the Planning Code Enforcement Unit.

The Department agrees. This will most likely require supplemental appropriation and support from the Mayor"s office and from the Board of Supervisors.

13.2 Emphasize the Planning Code enforcement responsibilities of the Neighborhood Planning Quadrant planners in order to assist the Code Enforcement Unit in bringing Planning Code enforcement under control.

The Department agrees. This will become a part of general staff training.

13.3 Ensure that the Code Enforcement Unit properly processes all Notices of Violations referred by DBI.

The Department agrees. This is already being carried out.

13.4 Ensure that existing means of cost recovery activities are pursued vigorously.

The Department agrees. However, many violations are corrected prior to the enactment of fines or the violation is corrected without the offender obtaining a building permit. Currently, for time and materials charges to be imposed, a building permit application is required.

13.5 Investigate the feasibility of obtaining new legislation to expand the types of Planning Code violations subject to the Planning Code Section 610 processes.

The Department agrees. In fact, the Department has already earmarked $42,000 in the FY 2002/03 budget for this purpose.

13.6 Conduct a review of the benefits and costs of requiring Notices of Special Restrictions on building code permits that have the potential for abuse, as was done in the recent past.

The Department agrees. This, however, will necessitate additional funding and staffing.