Permitting should not take longer than construction, but, in the city of Miami, that’s exactly how long it takes.
The first time I was in the Building Department at the City of Miami, I was permitting a simple wooden fence. I arrived a little after 1pm to the corridor where the “plan drop off” window was supposed to be. I circled the floor searching for someone to talk to, but everyone just seemed to be standing around. The chairs had scattered, disappointed, faces and the signage was seemingly pointed at nothing. I sat down and tried to find my bearings. I found the “plan drop off” sign but it appeared that a fabric panel had been pulled down where the counter should be. I looked around and saw forms on the counter, and soon found a small, discreet sign: “Office Closed for Lunch from 12:30-1:30 pm.” This anecdote represents only one of the many inefficiencies that I found at the Miami Riverside Center on the 4th Floor. If small businesses across Miami could open for lunch, why couldn’t a massive office building responsible for the collection of millions in tax dollars.
For those that don’t know, to permit a building you need the approval of 9 City Departments: Building, Mechanical, Electrical, Structural, Plumbing, Public Works, Flood Plain, Zoning, and Environmental Resources; and 2 County Departments: Environment and Water & Sewer. In order to begin, you fill out a paper application and bring it to the department to be opened and receive a Permit Number. After this, you drop off 2 full-size copies of the building set, one will go back to you, and 1 will eventually be filed at the city. The identical plans will then make their way physically from department to department, being assigned to various reviewers with expertise in each section of the building code, until it has completed its loop, with all of the comments for corrections able to be viewed online.
We submitted our plans for a 4,000 sqft duplex to the City of Miami on July 21st, 2017. Before I move on, I’d like to say that no set of plans is perfect, but this one was pretty darn good. It moved through the first 7 departments fairly quickly (3-5 days in each), most comments asked for information that was already given, that they did not appear to look for, and a few things we missed. The plans then spent 40 days in the Public Works Department, followed by another 23 days in the Zoning office. All in all, the first round to get through the city with 0 approved departments took 93 days.
We then submitted to the county departments, which were approved within a month, and then back to the city. We went back and forth a few rounds completing most all of the actual building related departments (electrical, mechanical, structural, etc.) by early 2018, but the persistently annoying and slow departments were Public Works, Zoning, and Environmental Resources.
With Public Works, the argument was over a 50′ wide sidewalk slope. The department asked that the sidewalk slope does not exceed 2% slope (which it didn’t) and that we show elevation points at the back of the sidewalk (which was not useful). So we resubmitted but were denied for the same sidewalk reason we have been, so we requested a meeting with the reviewer (taking a few weeks to coordinate). At our meeting, we showed that the sidewalk met all of the demands of the code asked for. The reviewer then changed his mind and said he didn’t want elevation points at the back of the sidewalk, but throughout it in a cross-section at multiple points to show that it met code. Granted we had a copy of the code diagram put on the site plan page so as to show that we intended to follow it.
This next time we attempted a “walkthrough” which is a process to answer comments immediately, without needing to drop off the plans. It is reserved for projects that only a few comments remaining. This process is one of the most oddly demeaning professional processes I’ve participated in: You sign up with your plans in your lap for all of the departments you’d like to see. You sit in rows of chairs so close your knees touch the chair in front of you as you await reviewers to appear out of the doors around you and say your name. They then grab the plans and whisk them to a backroom desk where you are not allowed to be while you wait, unable to explain where the corrections are or what you are supposed to do to remedy them. The reviewer then comes back out and just says “approved” or “denied” and calls the next name. If you do manage to corral the reviewer before they go to the back, you try and open the plans and show them something or ask a question over a crowded seat or copy machine before you lose their attention in 30 seconds, and they whisk your plans to the back. At this walkthrough, we got 2 approvals, and 2 denials, one of which, Public Works, did not agree to look at our plans as our reviewer was not doing the walkthroughs.
We then submitted to Public Works to review, and our previous reviewer assured us he would expedite it. He did not end up even reviewing it, and our sidewalk was again denied, and we again requested a meeting. We had a meeting, and essentially we had a 4 ft sidewalk drawn before the curb drop for a car, and their office had 2 pages of identical code: 1 showed a 3 ft sidewalk the other showed a 4. 4 is better as it gives more sidewalk space, but because one code sheet showed a 3 ft sidewalk, the reviewer could not see or accept a different, even better, result. He went to his boss, and agreed to accept it, but said he still needed us to re-submit it to accept it, even though he was requesting no changes. We resubmitted and after 19 days pending we finally got a Public Works Approval.
With Zoning, we had 2 persistent comments that were on the plans until they were approved in April 2017, but 2 new ones were added: Provide Demo permit (which is easily able to be looked up in their system) and provide setbacks to driveway (which takes a ruler to discover), and that it needs approval by Environmental Resources before it can be approved. We decided to focus on Environmental. The issues with Environmental comments weren’t substance but format. We finally got the format after we corralled the reviewer in a walkthrough (the comments are written annoyingly broadly), resubmitted and got an approval. At this point we attempted to walkthrough Zoning with our 2 comments, however, the walkthrough reviewer did not agree to see it as they said the project was valued over $500,000 (it wasn’t), and it then took 20 days to review and approve it. The plans then took 5 days in Final Quality Check and were pulled on July 18th, 2018, 3 days shy of a full year.
Many would read this story and feel little sympathy for developers who have to deal with the brunt of this burden, however, as building costs continue to rise, and favorable loans are difficult to obtain for small businesses, this burdensome process is contributing to the increase in the cost of living in the City of Miami. Small-scale developers are beginning to look at other places to build, bringing less building supply to Miami, while demand continues to rise. All of this cost is being passed on to the buyers and renters who will one day occupy these buildings, and contribute to our cities.
I have researched projects that are of a similar size and scope and my permit-time is actually shorter than average. At the end of 2018, the City of Miami is releasing a version of “Electronic Plan Review” where theoretically all departments can review a set of electronic plans simultaneously. This is one step in the right direction, but the system overall needs updating: reviewers need to learn to accept multiple formats of the right answer and their comments should be more specific if they expect a specific result; walkthroughs should allow space for explanation and discussion; Plans should allow for simultaneous review, and no department should take more than a week; And, finally, they should allow drop-offs and permit windows to be open over lunch.