Reforming Site Permitting

Project Details
March 23, 2023

San Francisco
Permit Center
Background
Under the Mayor’s Housing for All initiative and the San Francisco Housing Element, the City is
evaluating proposals to modernize and streamline permitting processes to reduce the timeline for getting
permits. This is a massive project, touching many different elements of City permitting. The Site Permit
update project is one part of this work and is focused on the Site Permit process.
Every construction project needs a Building Permit, and the Site Permit process is a way you can pursue
approval of the project at a high-level first, then follow up with construction level details in ‘addenda’
submittals. Today, Site Permits are used for projects that are large and complex or ones that need approval
by the Planning Department. Site Permits benefit applicants and the public. Applicants can gain certainty
that their project is approved before they invest in detailed drawings, and members of the public can
comment on project designs while they are still high-level enough to be amended.

The Problem
Completing the Site Permit review process takes too long, causes confusion to the public for appeals, and
does not create the right value for the City.

The permitting process is lengthy
and undefined. A Site Permit review
is a preliminary review based on
high-level drawings, but agency
comments are often not aligned to
the review (“scope-creep”).
Appeal timelines are misaligned.
To appeal a Discretionary
Review decision by the Planning
Commission, you can appeal the
issuance of the Building Permit.
It is impossible to plan when this
period will start.
Planning Commission review of
Building Permits happens before
other agencies review the permit,
so entitlement decisions are made
without the benefit of knowing if
issues existing with other codes.

Searching for Solutions

To identify ways to improve the Site Permit process, the Permit Center studied past permit review
performance and reviewed how peer jurisdictions in the State review land use permits. No other large
jurisdiction processes entitlement permits through a Building Permit process.

Sacramento has the Site Plan and Design Review process administered by Planning as a precursor to
applying for Building Permit. These may be reviewed at a staff level or require a hearing.
Oakland has tiers of Planning Department applications that serve as precursors to Building Permit,
such as Zoning Worksheet (ZW), Design Review Exception (DRX), Small Project Design Review (DS),
and Regular Design Review (DR). Each has different approval requirements.
San Jose has the Site Development Permit as a Planning Department precursor permit to applying
for a Building Permit. A single-family-house permit can be used for certain small projects (e.g.,
additions that are two stories or less with a Floor Area Ratio of 0.45 or less).
Los Angeles uses ministerial permitting (“as of right”) for a much higher portion of
projects. Large projects are required to obtain Site Plan Review approval by Planning
prior to applying for a Building Permit (e.g., 50+ unit buildings).
Long Beach also uses ministerial permitting for more projects and requires
Site Plan Review approval for larger ones but has lower thresholds for
requiring Site Plan Review approval (e.g., 5+ unit buildings).
San Diego requires a “Discretionary Permit” for certain projects and
project sites. For other projects, review can be ministerial. When a
Planning Permit is required, the City has multiple process types that
apply which set requirements without needing multiple permit types.
Smaller projects can be approved in Process #1 (staff decision), while
others require higher processes (such as a Commission approval).
Proposed Changes
Change #1: Re-creating the Site Permit process as a Planning Department process.
When we reviewed our peer jurisdictions, this was identified as a best practice. The Planning
Department taking over the processing of these permits also allows the assigned planner to act
as an overall permit coordinator, consolidating comments from other reviewing agencies into
one Plan Check Letter. With one city staffer coordinating the review, we can identify issues
and inconsistencies as they come up and provide a more coordinated response. Re-framing
this process as a Planning Department permit will also help to set clearer expectations of what
needs to be reviewed at this stage of permitting.
Change #2: Conducting a fully concurrent plan check prior to project entitlement.
If permits are reviewed by all City agencies concurrently, the overall permitting timeline can be
reduced. Applicants would also get a complete picture of City comments at once, so conflicts
between agencies can be identified early on. Conducting plan review concurrently also means
that the information provided by these agencies will be available for consideration when the
Planning Commission is reviewing the project. If there are Building or Fire Code issues with
a design, we can have those issues remedied before the entitlement approval (reducing the
amount of entitlement modifications needed).
Change #3: Setting clear guidelines of what is (and is not) reviewed under a Site Permit.
The existing Site Permit and Addenda model is intended to allow a project to be reviewed
and approved at a high-level first, then follow up with more detailed drawings in Addenda
submittals. In practice, this is not consistently applied to the review of permits. Permits are not
clearly distinguished between Site and Full Permits, so plan checkers often provide comments
that should be reserved for construction level permitting. This extends the overall timeline
of review, misaligns appeal periods, and is inconsistent with the general process of design of
buildings. Setting clear expectations for what is reviewed will enable applicants and staff to do
their work more efficiently and effectively.
Change #4: Providing applicants with a roadmap of post-entitlement permit requirements as
part of a Site Permit approval.
Building a project can require approval of multiple permits, but if an applicant misses the right
moment to apply for a post-entitlement permit (such as a Building Permit, Street Improvement
Permit, or Encroachment Permit), they may be delayed in starting construction. To help
applicants to navigate a complicated permitting system, we want to use the fully concurrent
plan review stage to set a roadmap on what post-entitlement permits and submittals will be
needed. This will ensure that nothing is missed and that needless delays are avoided.
Change #5: Conducting a fully digital review of these permits.
The City is currently working to establish an electronic plan review process. For this project,
we want to take it one level deeper to establish a fully digital process using the Planning
Department’s existing Accela implementation. An applicant would apply using a web form,
coordination of review would occur using Accela review tasks, and all review documents would
be stored in accordance with the Sunshine Ordinance. This improves the efficiency of review
and improves the transparency of the permitting process to the public.
SITE PERMITS TODAY

SITE PERMITS - POST-PROJECT

Frequently Asked Questions
Will this add even more process or bureaucracy?
No. This project is proposing to reduce and consolidate process, not add any new ones. Instead
of having two separate intake processes, there will be one. Instead of having to phases of plan
check, there will be one, with a planner consolidating all the City comments into one Plan
Check Letter.
Will permits get reviewed faster?
Yes. Permits will be reviewed by the City faster for three reasons. First, the project will
consolidate the duplicative permit intake processes into one intake with Planning. Second,
permits will be reviewed by every City agency concurrently. Applicants will get one full Plan
Check Letter from the City and will not need to respond to multiple cycles of review with
different groups of reviewers. Finally, the City will define what is and is not reviewed under
a Site Permit, so applicants know what they need to address to get their permit and City
reviewers understand what they really need to be reviewing. With these changes, we expect
the project will reduce the overall time to get a permit significantly.
Is the City’s review becoming less stringent?
No. The City’s overall review process will be maintained. However, for Site Permits, we will
make sure that comments to applicants are in-line with the stage of design that the projects
are in. Highly specific details like plumbing or electrical plans will be reviewed when fully
detailed construction plans are ready. This is the intent of Site Permits today but is not how
they’ve been processed in practice.
Will this change how appeals are handled?
No. Appeal options will stay the same. Today, someone can appeal the the issuance of a Site
Permit but cannot appeal any Addenda to that Site Permit. This will not change.
Are fees going to change?
Fees will stay the same, but you’ll pay your Planning Department review fees upfront when
applying for a permit.
Nothing will change about impact fees, which would still be due when you get a construction
permit.