HomeMy WebLinkAbout2025-02 DPW Building PermitsCounty of Hawai‘i
Office of the County Auditor
Report No. 2025-02
April 30, 2025
Department of Public Works
Building Permit Process
Hawaiʻi County is an Equal Opportunity Provider and Employer
April 30, 2025
Honorable Dr. Holeka Goro Inaba, Council Chair
and Members of the Hawai‘i County Council
Hawai‘i County Council
25 Aupuni Street
Hilo, Hawai‘i 96720
Dear Council Chair Inaba and Council Members,
We have completed our audit of the permitting and inspection processes at the Department
of Public Works, Building Division. This audit was conducted in accordance with generally
accepted government auditing standards and the Hawai‘i County Charter Section 3-18(d)(2).
The goal was to compare stated permit procedures with the actual user experience. This
evaluation assessed project elements, from permit application through final inspection, to
ensure a timely, accurate, and streamlined process compliant with applicable regulations
and service standards.
While the Building Division has been fully committed to enhancing its procedures and
software system, the audit found inconsistencies in documented processes, operating
practices, fragmented resource materials, and variability in its performance.
Several recommendations were made to strengthen operations, consolidate resource
materials, provide consistent performance, and establish internal controls. Addressing
these issues enables the Division to provide more equitable support to all users, ensure
smoother and more efficient permit processing, and enhance overall accountability,
resulting in improved satisfaction and trust from the community.
In response to a draft of this report, management expressed general agreement with our
results. Their complete response to this audit can be found on pages 93 – 131 Management
Response.
We appreciate the participation of management and staff in the Department of Public Works,
who shared their time and expertise during the audit. To improve government accountability
and ensure audit recommendations are implemented or resolved, we continuously monitor
the status of recommendations using our remediation tracker.
Tyler J. Benner
County Auditor County of Hawaiʻi Office of the County Auditor Ph 808.961.8386
County of Hawaiʻi Office of the County Auditor 120 Pauahi St., 309 Hilo, HI 96720 F 808.961.8905
www.hawaiicounty.gov
To view the department’s status, visit us at https://www.hawaiicounty.gov/our-
county/legislative/office-of-the-county-auditor.
If you have any questions or concerns about the status of the recommendations discussed,
feel free to contact me at 961-8386. Thank you.
Respectfully,
Tyler J. Benner
County Auditor
cc: C. Kimo Alameda, Ph.D., Mayor
William V. Brilhante Jr., Managing Director
Merrick Nishimoto, Deputy Managing Director
Neil Azevedo, Acting Director
Julann Sonomura, P.E., Building Division Chief
Aaron J. Spielman, AIA, Deputy Building Division Chief
Jon Henricks, County Clerk
Diane Nakagawa, Finance Director
i
Table of Contents
Report Highlights .............................................................................................. 1 - 3
Chapter 1 Introduction & Background
About Us ........................................................................................................... 4
Objective, Scope, and Methodology ............................................................... 5 - 6
Definitions .................................................................................................... 7 - 9
Noteworthy Achievements and Events ......................................................... 10 - 11
Background ............................................................................................... 12 - 22
Chapter 2 Audit Results
Dashboard: Status of Applications Submitted to Permits Issued
Without written documentation such as policies/procedure manuals, it becomes
extremely difficult to keep complex systems organized and predictable for permit staff
and applicants. The results is inefficiencies, personal preferences, and some level of
chaos creeping into the system. These items lead to non-predictability for permit
applicants which in turn leads to unnecessary complaints to upper management and
elected officials.
~James Tinner, Code Support Group
Application Volume ......................................................................................... 23 - 33
Finding 1: The Volume of Applications Contributes to Delays
Recommendation 1: Exempt Qualified Low-Risk Applications ........................... 33
Recommendation 2: Implement Self-Certification & Provide Public Duty Doctrine
Training ........................................................................................................... 33
Recommendation 3a: Pilot Third-Party Review Services During Peak Periods ........ 33
Recommendation 3b: Enhance AI Integration in Plan Review Processes ............... 33
Processing Time .............................................................................................. 34 - 59
Finding 2: The Permit System Launched Prematurely Before Full Configuration and
Optimization
Recommendation 4: Dedicate Pre-Screening Function ...................................... 38
Recommendation 5: Enforce Ascending Date-Driven Priority Protocol ................ 38
Permit Dashboard
ii
Finding 2: Permit System Launched Prematurely Before Full Configuration & Optimization
Recommendation 6: Strengthen Customer Education and Outreach ................... 41
Recommendation 7: Reduce Instances of Resubmissions .................................. 41
Recommendation 8: Monitor and Evaluate First-Pass Rates ................................ 41
Recommendation 9: Streamline Workflow Management ..................................... 54
Recommendation 10: Update Staff and Public Education Materials ..................... 54
Recommendation 11: Consolidate Reviews ....................................................... 54
Recommendation 12: Enhance Interagency Cooperation .................................... 54
Recommendation 13: Automate Invoicing and Issue Provisional Permits for
Construction Start ........................................................................................... 56
Recommendation 14a: Enforce Consistent Timeframes for Permit Evaluation
Process ............................................................................................................ 59
Recommendation 14b: Review and Update Administrative Rules to Establish
Maximum Timelines for Reviews ....................................................................... 59
Application Complexity ................................................................................... 60 - 80
Finding 3: Redundant Data Collection
Recommendation 15: Reduce Redundant Data Collection .................................. 76
Finding 4: Manual Processes Drive the Workflow
Recommendation 16: Eliminate Manual Processes ............................................ 76
Finding 5: No Contact Validation and Categorization
Recommendation 17: Validate and Categorize Contact Information .................... 77
Finding 6: Insufficient Clarity to Guide Data Collection
Recommendation 18: Refine “More Info” Screen ................................................ 77
Finding 7: Building Division Uses Outdated Forms
Recommendation 19: Eliminate Legacy Forms ................................................... 78
Finding 8: Not Utilizing Digital Signature Feature
Recommendation 20: Enable Digital Signatures ................................................. 78
Finding 9: Improve Accountability and Transparency
Recommendation 21: Define Application Completeness by Ordinance ................ 79
Recommendation 22: Implement a Formal Complaint Handling Process ............. 79
Recommendation 23: Integrate Lean Six-Sigma into Staff Development ............... 80
iii
Inspections Practices .......................................................................................... 81 - 89
Finding 10: No Policies and Procedures
Recommendation 24: Establish Policies and Procedures .................................... 85
Finding 11: Limited Management Oversight
Recommendation 25: Increase Management Oversight ...................................... 86
Finding 12: Lack of Training
Recommendation 26: Develop Training Program ................................................ 87
Finding 13: Lack of Critical Enhancements
Recommendation 27: Opportunities for Critical Enhancements .......................... 89
Chapter 3 Fraud, Waste, and Abuse ............................................................... 90 - 91
Conclusion ................................................................................................ 92
Chapter 4 Management Response .............................................................. 93 – 131
Attachments .............................................................................................. 132 - 141
Attachment A: Report Regarding Operations Within the Building Code Division of
the Hawai‘i County Public Works Department ................................................... 132
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1 | Report Highlights
Why The Office of the County Auditor (OCA) Conducted This Audit.
Hawai‘i’s housing crisis, driven by high home prices, limited affordable options, and an aging
housing stock, is exacerbated by a complex regulatory environment and systemic inefficiencies in
the building permitting process. The County of Hawai‘i’s Building Division is responsible for
safeguarding public safety through permitting and inspections. However, delays and enforcement
challenges, some of which are industry-wide and not unique to the County of Hawai‘i, have created
obstacles for residents, incentivized unpermitted construction, and undermined public trust.
In 2021, the County introduced the Electronic Permitting and Information Center (EPIC) system,
transitioning from a three-permit process (Building, Plumbing, and Electrical permits) to a
streamlined one-permit process. However, long wait times are still perceived, leading to ongoing
public frustration. A performance audit was initiated to evaluate whether internal controls and
processes function effectively to support fair and efficient permitting and inspection systems.
This audit aimed to align documented processes with user experiences, identify bottlenecks and
inefficiencies, and recommend improvements to enhance operational transparency,
accountability, and public trust in the permitting and inspection systems.
We found that the permitting system was launched prematurely while the Building Division was
still learning the system's capabilities and refining its one-permit process to the 2018 County Code.
However, experience gained over time, improvements to the workflow, and performance
monitoring continue to be the division’s top priority.
To strengthen internal controls and improve business processes, we make the following
recommendations:
Office of the County Auditor
April 2025
County of Hawaiʻi Performance Audit of the Department of Public Works
Building Permit Process
2 | Report Highlights
Finding 1: The Volume of Applications Contributes to Delays
To Address Application Volume
Workflow
Step
We make the following recommendation
All
1 Exempt Qualified Low-Risk Applications
2 Implement Self-Certification and Provide Public Duty Doctrine Training
3a Pilot Third-Party Review Services During Peak Periods
3b Enhance AI Integration in Plan Review Processes
Finding 2: The Permit System Launched Prematurely
Before Full Configuration and Optimization
To Address Application Time
To Improve
Workflow
Steps
We make the the following recommendation
Upload
Stage
4 Dedicate a Pre-Screening Function
Upload
Stage
Intake Stage
5 Enforce Ascending Date-Driven Priority Protocol
6 Strengthen Customer Education and Outreach
Intake Stage
Multi-
Agency
7 Reduce Instances of Resubmissions
8 Monitor and Evaluate First-Pass Rates
9 Streamline Workflow Management
Multi-
Agency
Out
Processing
10 Update Staff and Public Education Materials
11 Consolidate Reviews
12 Enhance Interagency Cooperation
13 Automate Invoicing and Issue Provisional Permits for Construction Start
Out
Processing
14a Enforce Consistent Timeframes for the Permit Evaluation Process
14b Review and Update Administrative Rules to Establish Maximum Timelines
for Reviews
3 | Report Highlights
Finding 3: Redundant Data Collection
To Address Application Complexity
To Improve
Workflow
Steps
We make the following recommendation
Location 15 Reduce Redundant Data Collection
Finding 4: Manual Process Drives the Workflow
Type
16 Eliminate Manual Processes
Finding 5: No Contact Validation and Categorization
Contact
17 Validate and Categorize Contact Information
Finding 6: Insufficient Clarity to Guide Data Collection
More
Information
18 Refine "More Info" Screen
Finding 7: Building Division Uses Outdated Forms
Attachments
19 Eliminate Legacy Forms
Finding 8: Not Utilizing Digital Signature Feature
Sign and
Submit
20 Enable Digital Signatures
Finding 9: Improve Accountability and Transparency
All
21 Define Application Completeness by Ordinance
22 Implement a Formal Complaint Handling Process
23 Integrate Lean Six-Sigma Training into Staff Development
To Address Gaps In Inspection Practices
Finding 10: No Policies and Procedures
To Improve
Workflow
We make the following recommendation
Inspection 24 Establish Policies and Procedures
Finding 11: Limited Management Oversight
Inspection 25 Increase Management Oversight
Finding 12: Lack of Training
Inspection 26 Develop Training Program
Finding 13: Lack of Critical Enhancements
Inspection 27 Opportunities for Critical Enhancements
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County of Hawaiʻi Of�ice of the County Auditor
Introduction &
Background
4 | About Us
About Us
Mission
It is our mission to independently serve the County Council and the citizens of Hawai‘i
County by promoting accountability, fiscal integrity, and transparency in local government.
We conduct performance and financial audits of County agencies and programs in
accordance with Government Auditing Standards.
The Office of the County Auditor examines the use of public funds, evaluates operations and
activities, and provides analyses, options, and recommendations to decision-makers in an
objective manner. Our work supports County government in managing public resources,
delivering public services, and upholding the public trust.
Audit Authority
Hawai‘i County Charter §3-18 establishes an independent audit function within the
Legislative Branch through the Office of the County Auditor (OCA).
Purpose
The audit evaluated the efficiency and effectiveness of the County of Hawai‘i’s building
permit process by aligning stated permit procedures with the actual user experience. We
assessed project elements, from permit application through final inspection, to ensure a
timely, accurate, and streamlined process compliant with applicable regulations and
service standards.
Performance Audit Definition
Performance audits provide objective analysis, findings, and conclusions to assist
management and those charged with governance and oversight with, among other things,
improving program performance and operations, reducing costs, facilitating decision-
making by parties responsible for overseeing or initiating corrective action, and contributing
to public accountability.
Our objective in performance auditing is to improve public services provided by the County
government. We do this by recommending specific actions to address the issues we raised
and by providing valuable information to the public, the administration, program leadership,
the county council, and the mayor.
5 | Objective, Scope, and Methodology
Objective, Scope, and Methodology
Objective
Do the internal controls at the Department of Public Work’s Building Division ensure the
timely issuance of building permits and compliance with Chapter 5 of the Hawai‘i County
Construction Administrative Code?
Scope
The audit was conducted from September 2023 to April 2025, we:
• Evaluated Electronic Processing and Information Center (EPIC) datasets from July 26,
2021, to March 31, 2024
• Evaluated permit processes and practices from September 2023 to April 2025
While the Building Division (BD) tracks timelines based on specific review criteria, the audit
included all applications in the queue for the specified time. This results in differences in
how application timelines were calculated between BD and OCA.
We did not evaluate:
• “Legacy Permits” permits evaluated outside or before EPIC (July 26, 2021)
o Permits issued in Lotus Magnet, and hardcopy submissions
• Engineering Only
• Permit Metric Reports
• Cash handling processes
Methodology
To accomplish our objective, we:
• Developed an understanding of the County’s building permit policies and
procedures, practices, and processes from intake to final inspection
• Analyzed internal control systems and control environment
• Assessed compliance with applicable laws, rules, and other relevant governance
• Conducted stakeholder interviews
• Corroborated information with appropriate staff
• Attended “How to Reduce Building Permit Delays in Hawai‘i” seminar
• Reviewed, as needed, information pertinent to the building permit process
• Conducted site visits to observe workflows and inspection practices
• Noted exceptions and made recommendations
• Was mindful of potential fraud, waste, and abuse as it relates to the audit objective
• Conducted this performance audit in accordance with Generally Accepted
Government Auditing Standards
6 | Objective, Scope, and Methodology
These standards require that we plan and perform the audit to obtain sufficient and
appropriate evidence to provide a reasonable basis for our findings and conclusions based
on our audit objectives. We believe that the evidence obtained provides a reasonable basis
for our findings and conclusions based on our audit objectives.
7 | Definitions
Definitions
ADA: The Americans with Disabilities Act is a federal civil rights law that prohibits
discrimination against people with disabilities in everyday activities. The ADA prohibits
discrimination on the basis of disability, just as other civil rights laws prohibit discrimination
on the basis of race, color, sex, national origin, age, and religion. The ADA guarantees that
people with disabilities have the same opportunities as everyone else to enjoy employment
opportunities, purchase goods and services, and participate in state and local government
programs.
BD: The Building Division oversees the administration, review, coordination, and
enforcement of building codes within the County of Hawai‘i. Responsible for the repair and
maintenance of County-owned buildings. Responsible for contracting building repair,
renovation, and new facilities construction.
BLUEBEAM STUDIO: Bluebeam is a software application used by professionals in
construction, architecture, and engineering. It is designed for creating, editing, marking up,
and collaborating on PDFs, with features tailored to streamline project documentation and
workflows.
DEM-WW: The Department of Environmental Management Wastewater Division is
responsible for the operation and maintenance of 120 miles of sewer mains, 16 pump
stations, 7 treatment facilities, and the closure of the large-capacity cesspools. The
wastewater division accepts 5 million gallons of wastewater for treatment daily and cleans
and inspects approximately 20 miles of sewer lines annually.
DOH: The State of Hawai‘i’s Department of Health functions under the leadership of the
State Director and Deputy Director and includes attached offices and agencies. Most DOH
programs are under one of three administrations: health resources, environmental health,
and behavioral health.
EPL: Electronic Permitting System or e-Permitting Portal is a software system that allows
state and local permitting authorities to submit permits electronically and supporting
documents to regulatory authorities.
8 | Definitions
EPIC: The County of Hawai‘i’s Electronic Processing and Inspection Center powered by
EnerGov to better serve the public. EPIC helps:
• Tracks and manages plan applications and requests and Building and Engineering
permit applications received by both departments
• Allows community members to submit a number of plan applications, engineering
grading, grubbing, stockpiling permit applications, and building permit applications
online.
• Accepting electronic plans allows multiple approving agencies to review the plans
concurrently. Once a building permit is issued, contractors can request inspections
and view the results of the inspections online.
• To improve transparency, customers can track the application’s progress as it is going
through the approval process online. Support of credit card and electronic check
payments online.
INSPECTIONS
FOUNDATION/SLAB INSPECTION: County Code, Chapter Five, Section 5-8-4 (2) and (3),
Inspections state the following conditions need to be met for foundation/slab inspections:
• (2) Footing and foundation inspections shall be made after excavations for footings
are complete and any required reinforcing steel is in place. Any required forms shall
be in place for concrete foundations before inspection. Materials for the foundation
shall be on the job, except where concrete is ready mixed in accordance with ASTM C
94; the concrete need not be on the job.
• (3) Concrete slab and under-floor inspections shall be made after in-slab or under-
floor reinforcing steel and building service equipment, conduit, termite spray, vapor
barriers, piping accessories, and other ancillary equipment items are in place, but
before any concrete is placed or floor sheathing installed, including the subfloor.
FRAMING INSPECTION: County Code, Chapter Five, Section 5-8-4 (4) Inspections state the
following conditions need to be met for framing inspections: Framing inspections shall be
made after the roof deck or sheathing, all framing, fireblocking, and bracing are in place and
pipes, chimneys and vents to be concealed are complete and the rough electrical, plumbing,
heating wires, pipes, and ducts are approved.
FINAL INSPECTION: County Code, Chapter Five, Section 5-8-5 (a) and (b) state the
following:
• The final inspection shall be made after all work the permit requires is completed.
• A certificate of inspection may be issued upon request by the contractor on record,
provided all fees required by the construction code have been satisfied.
(2020, ord 20-61, sec 2.)
9 | Definitions
IECC: The International Energy Conservation Code addresses energy efficiency on several
fronts, including cost, energy usage, use of natural resources, and the impact of energy
usage on the environment.
IRC: The International Residential Code is a comprehensive, stand-alone residential code
establishing minimum regulations for one- and two-family dwellings and townhouses using
prescriptive provisions. It is founded on broad-based principles that make the use of new
materials and new building designs possible.
IWS: An Individual Wastewater System - an on-site system for treating and disposing
wastewater. Approved IWS treatment equipment includes a septic tank, aerobic treatment
unit, passive aerobic systems that still require a septic tank, bioreactor garden, composting
toilets, and incinerator toilets. Composting toilets and incinerator toilets only treat toilet
waste. Shower and kitchen wastewater still require treatment and disposal.
Legacy System: Refers to a holdover from the past. It could be a system, process, or even a
mindset. In the workplace, it often describes older methods or technologies that were useful
in their time but might now be outdated or inefficient compared to newer options.
NEC: The National Electrical Code, also known as NFPA 70, is the U.S. standard for the safe
installation of electrical systems.
NESHAP: The National Emission Standards for Hazardous Air Pollutants are the stationary
source standards for hazardous air pollutants (HAPs). HAPs are those pollutants that are
known or suspected to cause cancer or other serious health effects, such as reproductive
effects birth defects, or adverse environmental effects.
NFPA: Established in 1896, the National Fire Protection Association is the authority on fire,
electrical, and building safety.
SHPD: The State of Hawaiʻi Historic Preservation Division is comprised of three branches,
Architecture, Archaeology, and History and Culture, and together they collectively strive to
preserve and protect Hawaiʻi’s historic identity.
UPC: Designated as an American National Standard, the Uniform Plumbing Code is a model
code developed by the International Association of Plumbing and Mechanical Officials
(IAPMO) to govern the installation and inspection of plumbing systems.
10 | Noteworthy Accomplishments & Events
Noteworthy Achievements and Events
We are pleased to report that the Department of Public Works Building Division (BD) has
taken proactive steps to enhance the permitting process, addressing certain control
weaknesses on its initiative and identified during the audit. We appreciate BD’s cooperation
and commitment to aligning with industry best practices. Specifically, BD has reported the
following actions:
• Participated in the Mayor’s Building Permit Task Force to improve the building
permit system. Members of the task force include contractors, drafters, realtors,
architects, engineers, and county staff (January 2025)
• Compiled a list of the top five rejection comments to release a FAQ or memo
aimed at assisting the public with common errors (January 2025)
• Hired a Permit System Coordinator (August 2024):
o Completed various training guides
o Created a training calendar, program syllabus, and instructional videos for staff
o Provided hands-on training to intake teams
• Configured automated emails to remind customers of pending permit applications
and statuses that require their action, including:
o Email reminder to pay Building Permit Plan Review Fees (December 2023)
o Email reminder to resolve permit conditions for applications (November
2023)
o A reminder that the application is about to expire:
30-day notice
90-day notice
o A reminder that the permit placard is about to expire:
60-days notice
• Hired an Information Systems Analyst (October 2023):
o Completed various EPIC system enhancements
o Began developing an inspection workflow
• Provided Cloud + Delta memo to enhance the plan resubmittal process (October 2022)
11 | Noteworthy Accomplishments & Events
• Implemented lead time tracking for application uploads, including:
o Established date-driven queues in July 2023
o Introduced date ticklers to manage pending applications < 30 days (April 2024)
Facilitated weekly brainstorming meetings to promote process improvement (October
2022)
We conduct follow-ups at the appropriate time to assess whether all recommendations
have been implemented or resolved and to what extent.
12 | Background
Background
What permit challenges exist in Hawaiʻi?
Hawai‘i faces a growing housing crisis, marked by surging home prices, a lack of affordable
options, and an aging housing inventory—38 years on average as of 2024. The state’s
highest-in-the-nation regulatory environment exacerbates these challenges, compounding
delays in new construction and repairs while driving some residents to seek more affordable
alternatives out-of-state. Environmental catastrophes have further strained housing
availability, wiping out entire communities and highlighting the urgent need for efficient and
effective building oversight.
BD plays an important role in coordinating efforts among multiple agencies to safeguard
public safety and welfare by regulating most structures' design, construction, and
maintenance. However, systemic inefficiencies and limited enforcement capacity hinder its
ability to fulfill this mission. These challenges burden residents navigating complex
permitting processes, encourage unpermitted construction that may pose safety risks, and
result in lost property tax revenues that could otherwise support essential public services.
In its current state, the system risks worsening Hawai‘i’s housing dilemma, underserving
residents, and undermining public trust. Addressing these issues is essential to ensure a
fair, efficient, and equitable process that balances safety, sustainability, and accessibility,
ultimately supporting the County’s broader goal of fostering a thriving community.
Permits are required for most building, electrical, and plumbing work involving a building or
structure. This includes new construction, additions or alternations, repairs, renovations,
and demolitions. The BD’s purpose is “to provide minimum standards to safeguard life or
limb, health, property, and public welfare by regulating and controlling the design,
construction, quality of materials, use and occupancy, location and maintenance of all
buildings and structures within the County and certain equipment.”1
What is the EPIC system?
The county launched its Electronic Permitting and Information Center (EPIC) system in July
2021. Developed over five years at a cost exceeding $2.5 million, EPIC is a paperless
permitting system designed to streamline the building permit application and review
process. It allows applicants, such as homeowners, contractors, and developers, to submit
1 Hawaii County Building Code Section 5A-1-2. Purpose.
https://www.hawaiicounty.gov/home/showpublisheddocument/302737/637853542567970000 Date accessed: 1/31/25
13 | Background
applications, upload documents, track permit status, and communicate with staff online.
EPIC also allows multiple agencies to review the permit application simultaneously. The
transition to EPIC marked the end of paper applications, with the county no longer accepting
them as of July 2021. Kiosks are set up at the Hilo and Kona Building offices to assist the
public with application submissions and system learning.
Training videos and an informational webinar are offered to help users learn how to navigate
the system.
Figure 1: Electronic Processing and Information Center (EPIC) homepage
How much revenue did the Department of Public Works generate from building
permits?
In fiscal year 2022-23, residential and non-residential building permits generated
$5,010,769.76 in revenue.
Why were building permit processes selected for review?
In Hawai‘i, permit delays present a significant challenge, with residents frequently facing
wait times of months or even years for approvals. The new electronic permitting system,
EPIC, was introduced to improve the process. However, long wait times (Figure 1.4, page 18)
and challenges within both the system and its processes have contributed to ongoing public
skepticism.
A performance audit of DPW building permits was included in the Office of the County
Auditor’s (OCA) fiscal year 2024-25 annual audit plan. We determined that a thorough
evaluation of the County’s building permit processes was warranted to determine if the
internal controls system worked as designed.
14 | Background
In 2022, the County contracted James Tinner of Code Support Group to analyze the
permitting processes. The objective was to assess BD’s workflow to identify redundancies
and reduce application approval times.
Tinner identified key contributors to delays and made 12 recommendations in a Report
Regarding Operations within the Building Code Division of the Hawaii County Public Works
Department (“Tinner Report”). He concluded that “Permit processing systems are extremely
complex. Without written documentation such as policies/procedure manuals, it becomes
extremely difficult to keep complex systems organized and predictable for permit staff and
applicants. The results is inefficiencies, personal preferences, and some level of chaos
creeping into the system. These items lead to non-predictability for permit applicants which
in turn leads to unnecessary complaints to upper management and elected officials.”
(Attachment A)
Separately, the Grassroot Institute of Hawai‘i, a nonprofit policy research group dedicated to
promoting accountable government, researched and published a report identifying and
proposing seven low-cost solutions to expedite building permits. These include:
• Allowing preapproved building plans
• Exempting basic work that does not pose major safety risks
• Streamlining solar project approvals
• Grandfathering unpermitted dwellings
• Allowing third-party approvals and issuing certain building permits
• Adopting “shot clocks”
• Reducing fees
The Grassroots methodology involved analyzing permitting practices, consulting industry
stakeholders, and comparing regulatory frameworks in other regions to develop practical
recommendations.
15 | Background
The solutions proposed by BD and external groups represent a broad spectrum of options to
improve the building permit process. While some solutions overlap, others may contradict
each other. This summary does not endorse or express an opinion on any specific solution
but highlights areas of agreement and divergence for consideration.
Figure 1.1: Proposed Solutions Across Stakeholders
Figure 1.1: Proposed Solutions Across Stakeholders, Compiled Office of the County Auditor
Tinner Report
Grassroots Institute Building Division Initiatives
ORD Define Complete App
Add Tech Fee
Reduce Fees
Add 3rd Party Plan Reviewers
Increase Plan Review Fees
Lean Processing
Public Duty Doctrine Training
Added 2 FTEs
Overtime to Clear Backlog Allow Preapproved
Building Plans
Exempt Low
Risk Permits
Grandfather Unpermitted Dwellings
Adopt Time Bound “Shot Clocks”
Digital Placard
Streamline PVs
Eliminate Bluebeam Sessions
Weekly Brainstorming Mtg
Enhance Map/GIS Features
Ensure BD Leadership Attends ICC Committee Meetings
Conduct Combo Inspections and Reviews
Amended Code Simplies
Cancellations, Expirations, and
Extentions (ORD 23-87)
16 | Background
Types of Permits.
Project applications are classified into five main categories and divided into 32 specific permit
types.
Figure 1.2: Types of Permits
Building - Non-Residential (11) Building - Residential (12)
Addition Model Home Design Pre-Approval
Alteration Addition
Demolition Alternation
Electrical Only Demolition
Emergency Demo/Repair/Reconstruction Electrical Only
Move Emergency Repair/Reconstruction
New Construction Move
Plumbing Only New Construction
Photovoltaic Plumbing Only
Swimming Pool/Hot Tub/Jacuzzi Photovoltaic
Temporary Structure Building Solar Water Heater
Swimming Pool/Hot Tub/Jacuzzi
Regulatory Inspections (5)
Adult Day Care Liquor
After School Program Preschool
Day Care
Grading, Grubbing, Stockpiling (3)
Grubbing Stockpiling
Grading
Sign (1)
Sign Figure: 1.2: Types of Permits. Department of Public Works Building Division
17 | Background
Comparisons of Permit Applications vs. Approvals.
We analyzed 15,575* application uploads from the EPIC system spanning July 2021 through
March 2024 to evaluate submission trends and performance measures. During this period,
the BD issued 11,134** permits. The blue line represents the number of permit applications
submitted, while the yellow line reflects the number of permits issued over the same
timeframe.
Figure 1.3: Permit Applications vs. Approvals Over Time*
Figure 1.3: Permit Applications vs. Approvals Over Time. Compiled Office of the County Auditor
*Note: A total of 16,364 permits were reviewed less 786 Engineering Only permits were excluded from the
review. Additionally, 2 Agricultural Exemption Permits, and 1 MSO Working Permit was removed, resulting in
a net total of 15,575 permits. Permits issued in Lotus, Magnet, Legacy, or hardcopy submissions were not
evaluated.
**Reports from DPW, EPIC System Report, and Auditor's Request for Permit Applications for the period July
2021 to March 2024.
Office of the County Auditor Permit Dashboard. https://www.hawaiicounty.gov/our-
county/legislative/office-of-the-county-auditor/audit-reports. Data provided by Building Division. Compiled
Office of the County Auditor.
Permit Dashboard
18 | Background
Figure 1.4: Online Permit Application Volume, Type, and Time *
Legend: Avg days 114.8 +/- 5 days of mean. < 5 days below mean >5 days above mean
Figure 1.4: Online Permit Application Volume, Type, and Time. Compiled Courtesy County Auditor
*Auditor Note: We did not evaluate permits issued in Lotus, Magnet, Legacy, or hardcopy submission. Source: Report
Provided by DPW EPIC, System Report. “Auditor Request for Permit applications between July 2021 to March 2024. OCA
Permit Dashboard. https://www.hawaiicounty.gov/our-county/legislative/office-of-the-county-auditor/audit-reports.
Data provided by the Building Division. Compiled Office of the County Auditor.
Permit Dashboard
19 | Background
Figure 1.4 represents the volume of applications received during the period. The average
processing time reflects the interval between the date applications are uploaded and
permits issued. This calculation includes time spent with both the department and the
customer.
This approach differs from the division's methodology, which calculates processing time
from task assignment to completion. During the audit period, the division did not track or
account for the time spent with the applicant, as this time is outside their direct control. Our
methodology, which considers the entire process from applicant submission to permit
issuance, better reflects user expectations for overall turnaround time2.
Building Permit Processes.
We examined the division’s building permitting practices for both residential and non-
residential permits. To account for process variations based on permit type, we used the
new construction residential process as a baseline to establish a foundational
understanding.
BD has educational materials it provides to the public to outline aspects of its building
permit process. Figure 1.5 was designed to maintain legacy processes in which paper plans
were reviewed sequentially, and a three-permit system was used. For example, the
residential permit steps are visually outlined below, comprising seven simple steps.
Building Division’s Residential Building Permit Process
Figure 1.5: Building Division’s Residential Building Permit Process
2 DPW Building Division. Comparison of the Average Number of Days to Process Permits.
https://records.hawaiicounty.gov/weblink/1/edoc/140091/BLG_Permit_Issuance_Metrics.pdf Accessed: 12/27/24
20 | Background
Figure 1.6 shows what the one-permit system is:
Figure 1.6: DPW Building Permit Process. Compiled Office of the County Auditor
21 | Background
1a. Submit Application.
Property owners, contractors, or agents applying on their behalf prepare an application by
creating a profile in the EPIC system and submitting it through the online portal. The
application includes selecting and describing the project type, identifying professional
trades, detailing building specifications, completing external forms such as a property
owner declaration and site plans (blueprints), signing the submission, and submitting the
application.
1b. Pay Plan Review Fee.
A plan review fee is charged at the time of application submission in addition to the permit
fee. This fee is 20% of the permit fee, with a minimum charge of $50. The fee must be
submitted along with the application, plans, and specifications required under HCC §5-4-1.
1c. Completeness Check.
The intake staff reviews the application. If complete, the application is routed for review. If
it is incomplete, additional information is requested through an email from the intake clerk.
2. Resubmit.
When it is ready to be reviewed, applications are received by a ten-member intake team.
Team members self-assign applications and check for completeness. Teams are expected
to prioritize the oldest applications first, advancing those with approvals or returning
incomplete applications to the applicant for corrections or resubmittals. If the application
is deficient, the applicant is notified by email of deficiencies that need corrections. After
corrections have been made, the application re-enters the queue for re-evaluation.
3. Land Use/Multi-Agency Review.
When approved at intake, the application progresses to the Planning Department for a land
use review. This review ensures that the property type suits the zoning and required
setbacks. Land use review is not required for all permit types, such as Electrical or
Plumbing-Only Permits.
The application then moves to a multi-agency review. During this stage, multiple agencies
work in parallel, and the agencies involved depend on the type of permit being sought. These
may include Plumbing, Department of Health (DOH)-Wastewater (if the plan calls for an
individual wastewater system), DOH-Food Safety reviews all non-residential projects,
Engineering, Fire (for non-residential projects only), Electrical, Mechanical, Structural,
Department of Environmental Management (if the plans call for a connection to a County
Sewer System).
22 | Background
The workflow is designed to notify all agencies when an application is disapproved, and
subsequent resubmittal may be required to address any changes.
Once all agencies involved in the multi-agency review have approved the application, it
proceeds to the out-processing stage, where the plans are reviewed again for completeness.
4. Resubmit.
At any stage of the review process, an application may be returned due to incorrect or
incomplete information caused by the applicant or staff errors. In either case, the applicant
is notified. Once corrections are received, the application re-enters the queue for re-
valuation. This “reset” can occur multiple times.
5. Approved for Issuance.
All steps have been completed, and pending some housecleaning the applicant is greenlit
for a permit.
6. Payment Pending.
The applicant is invoiced, payment is collected, and the applications again enter a queue
awaiting issuance.
7. Permit Issuance.
The application qualifies for issuance once payment and required project declarations are
received.
8. Permitted Inspections.
Permitted projects under construction require oversite by county inspectors at various
stages of construction. For example, once permits are approved, a residential new
construction project undergoes multiple inspections (in order of inspections):
• Foundation (Building, Electrical, Plumbing)
• Framing (Building, Electrical, Plumbing)
• Final Inspections (Building, Electrical, Plumbing)
In accordance with Hawaiʻi County Code § 5-8-3, only the contractor/owner builder, electrical
contractor, and plumbing contractor can request an inspection. Once construction is completed and
the dwelling passes final inspections, the permit is closed, and occupancy can occur.
Certificate of Occupancy (CO).
COs only apply to nonresidential construction. These structures cannot be used or
occupied, nor can the occupancy classification be changed until the appropriate authority
has issued a certificate of occupancy.
County of Hawaiʻi Of�ice of the County Auditor
Chapter 2: Audit Results
Volume
23 | Audit Results
Audit Activity.
To identify bottlenecks in the permitting process, we:
• Analyzed EPIC-generated datasets from July 26, 2021, through March 31, 2024,
including 15,575 permits, with an estimated valuation of $3,367,225,8853
• Reviewed Hawai‘i County Code Chapter 5 Construction Administrative Code, “Tinner
Report4,” and the Grassroots Institute of Hawai‘i Policy Brief5 (October 2024)
• Researched the Public Duty Doctrine
• Benchmarked other municipalities that use self-certification and/or third-party
review services
o City of Phoenix, AZ
o City of Denver, CO
o City of Fort Worth, TX
One obstacle affecting permits is volume. High permit application volume can overwhelm
the system, causing delays and backlogs. Efficiently managing large volumes ensures timely
processing and prevents bottlenecks.
Application Volume.
Figure 2 shows the volume of applications and the number of permits being issued.
Applications received (blue line) and permits processed (yellow line) over time do not
account for withdrawn, canceled, or expired permits. Lines remain parallel to one another
when a system is functioning optimally. When the lines intersect, it indicates that the
division’s capacity exceeds demand, and when the lines diverge, demand is outpacing the
division's ability to process applications.
3 Office of the County Auditor Permit Dashboard. https://www.hawaiicounty.gov/our-county/legislative/office-of-the-county-
auditor/audit-reports. Data provided by Building Division. Compiled Office of the County Auditor.
4 James Tinner, “Consultant’s Report: COM 36.1 (2022-24)” https://records.hawaiicounty.gov/Weblink/0/doc/1049842/Page1.aspx.
Accessed 11-20-24
5 Grassroots Institute of Hawai‘i. Policy Brief, (October 2024), Seven low-cost ways to speed up permitting in Hawai‘i Expediting the
issuance of building permits is critical to making a dent in Hawaii’s housing crisis. https://www.grassrootinstitute.org/wp-
content/uploads/2023/12/241007_pb_permits.pdf. Accessed 11/20/24
24 | Audit Result
Figure 2: Application Volume Outpaces Permit Issuance
Figure 2: Application Volume Outpaces Permit Issuance, data extracted from EPIC,
Analyzed Office of the County Auditor, Figure 2 does not include resubmittal.
Office of the County Auditor Permit Dashboard.
https://www.hawaiicounty.gov/our-county/legislative/office-of-the-county-auditor/audit-reports
Data provided by the Building Division. Compiled Office of the County Auditor
As of March 31, 2024, the volume of applications (blue line) and the division’s processing
capacity (yellow line) were on divergent paths. To address this issue, solutions should focus
on reducing the volume of applications requiring reviews, increasing the division’s capacity
to process applications or a combination of both strategies.
Permit
Dashboard
25 | Audit Result
Municipalities nationwide face unique housing challenges, prompting the development of a
wide range of proposed solutions to expedite permit processing at both state and local
levels. Following the launch of the EPIC system, the Roth administration contracted the
“Tinner Report,” which focused on an analysis of “current permitting processes”. The
Grassroots Institute of Hawai‘i also published a Policy Brief in October 2024 proposing
solutions to expedite permit issuance. Similarities between solutions are outlined below to
reduce volume and increase capacity:
Figure 2.1: Solutions Designed to Reduce Volume
Grassroot Institute of Hawai‘i6 Tinner Report7
Exempt basic repairs and other
nonstructural work that does not pose
major safety risks.
Reserve internal licensed engineering staff
for complex structures and allow licensed
design professionals to self-certify
conventional single-family homes,
reducing inefficiencies and addressing risk
intolerance through Public Duty Doctrine
training.
Exempt qualifying rooftop photovoltaic
systems from building permits.
Exempt rooftop photovoltaic systems
meeting established criteria from requiring
a licensed design professional.
Only an electrical permit with fire access
verification is required by the electrical
inspector.
Figure 2.1: Solutions Designed to Reduce Volume. Complied Office of the County Auditor
Photovoltaic (PV) applications accounted for a significant portion (25%) of the total
workload, representing 3,922 of the 15,575 applications. If PV systems were exempted, the
total applications would reduce to approximately 11,653, comparable to the 11,134 permits
issued during the review period. Since PV systems generally have faster turnaround times,
removing them from the workflow should free up resources to focus on more complex
projects requiring greater effort and processing time.
Increasing resource availability would shorten the average time for more labor-intensive
applications. However, the overall number of permits processed might decrease as the
system shifts from handling simpler tasks to prioritizing more complex applications.
6 Grassroots Institute of Hawai‘i. Policy Brief, (October 2024), Seven low-cost ways to speed up permitting in Hawai‘i Expediting the
issuance of building permits is critical to making a dent in Hawaii’s housing crisis. https://www.grassrootinstitute.org/wp-
content/uploads/2023/12/241007_pb_permits.pdf. Accessed 12-27-24
7 County of Hawai‘i. COM 36.1 Supporting material for Communication 36
https://records.hawaiicounty.gov/Weblink/0/doc/1049842/Page1.aspx Accessed: 12-27-24
26 | Audit Results
BD processes PV permits for systems under 10 kW, contributing to the volume of
applications. Exempting these systems from permitting could provide significant
reductions. Ordinance 24-93 Bill 212 (Draft 1) separately raised the dollar threshold for
certain non-structural permits from $7,500 to $25,000, further easing the workload. Both
reflect policy choices with the potential to substantially lower application volume.
Self-Certification.
Self-certification allows qualified professionals to confirm that their work meets building
codes, speeding up permit approval without full government review. The Tinner Report
discussed this concept, which noted BD’s extreme risk intolerance and preference to review
nearly all proposed work, except where exemptions are defined under HCC §§5-3-21 through
5-3-25. BD expressed concerns regarding high error rates and incorrect submissions by
licensed design professionals. These conditions emphasize building a collaborative
relationship with design professionals, setting clear expectations, and gradually fostering
trust to ensure accurate and reliable permit submissions.
Self-Certification Program.
We benchmarked the City of Phoenix, Arizona, which uses a self-certification program.
To qualify for self-certification, licensed architects and engineers must meet the following
eligibility requirements:
1. Have at least three years of professional experience in building code compliance
2. Be a registered professional within the state
3. Successfully complete the city's self-certification training course. This training must
be renewed every three years and includes requirements to:
a. Obtain and maintain sufficient professional liability insurance
b. Complete the necessary training classes
Requirements for Self-Certifying Projects.
Licensed architects or engineers must maintain the following documentation:
• Proof of adequate professional liability insurance
• A certification statement confirming eligibility for self-certification, a clean record
free of fraud or similar violations, and compliance with self-certification
requirements for the project
• A letter from the property owner or tenant stating they have authorized the work will
correct any errors or misrepresentations and will undertake necessary remedial
actions to ensure compliance with the law
27 | Audit Results
• A “hold harmless” letter indemnifying the city against any costs or damages arising
from the design, construction, code compliance review, or permit issuance for the
project
• A completed self-certification application
Audits and Inspections.
Self-certified projects are subject to the following review processes by the municipality to
ensure compliance:
• Random Audits: At least 10% of self-certification applications undergo a random
audit.
• Automatic Audits: Certain types of projects are automatically audited, including:
o Remodels of 25,000 square feet or more
o Shell buildings of 25,000 square feet or more
o New buildings of 10,000 square feet or more
o New electrical and instrumentation occupancies
o Public assembly occupancies with a capacity of 300 or more
o Medical marijuana facilities
o Ambulatory care facilities
o An initial review of standardized plans intended for repeated use
After plan approval and commencement of work, inspections are conducted to verify that
construction aligns with the approved plans. This combination of audits and inspections
helps identify and resolve compliance issues within the self-certification process.
Streamlined Permit Approval.
Once the design professional meets all eligibility
requirements and submits the necessary
documentation, the permit approval process can be
completed within one to five days.
In addition to the existing controls implemented in the
City of Phoenix's self-certification program, other internal
controls that could further enhance the robustness of
such a program might include the following:
• Program pilot and phased implementation
• Standardized checklists
• Publicly accessible code interpretations
• Post-audit improvement mechanisms
• Automated compliance validation tools
• Continuous feedback and revision
• Robust accountability measures
• Escalating penalties for non-compliance, including decertification
For Approved Self-
Certified
Professionals, the
permit approval
process can be
completed within
one-to-five days.
28 | Audit Results
• Partnerships with professional organizations
• Public-private oversight mechanisms
• Annual program review
Public Duty Doctrine Training.
The Public Duty Doctrine limits liability for government agencies performing public
functions, such as approving application packets or conducting inspections. Under this
doctrine, liability for construction failures is generally a civil matter between the contractor
and citizen, as the government’s duties and responsibilities are to the public, not individuals.
However, a government entity may assume additional liability when it makes independent
assessments of design professionals' work rather than simply verifying that required
documents are on file and accurate.
Training in the Public Duty Doctrine can help staff better understand the limits of their
responsibilities and reduce unnecessary liability exposure.
Currently, intake staff and plan reviewers are supervised by a licensed professional.
However, staff without professional licenses are making judgments on work submitted by
design professionals without continuous training to evaluate complex or technical details.
Figure 2.2: Solutions Designed to Increase Capacity
Grassroot Institute of Hawai‘i and Tinner Report
Allow third parties to approve and issue certain building permits and/or allow third-party
plan review services.
Figure 2.2: Solution Designed to Increase Capacity. Compiled Office of the County Auditor
Third-Party Review Services.
Third-party services involve external organizations or professionals hired to perform specific
tasks or functions, such as plan reviews and inspections, on behalf of a municipality to
enhance efficiency and expertise in the permit process. Third-party reviews can take various
forms, depending on model adoption and organizational needs.
On one end of the spectrum, municipalities may pursue a strategy of Business Process
Outsourcing plan review functions to organizations, which manage permit submissions,
customer service, and administrative tasks. This model focuses on efficiency and
scalability, making it suitable for jurisdictions facing high application volumes or limited
resources. For example, the City of Denver, Colorado, uses this approach to scale permit
review processes.
Alternatively, some municipalities, such as Fort Worth, Texas, have adopted a third-party
certification model. The City of Fort Worth maintains a local roster of at least eight certified
firms authorized to perform plan reviews and inspections.
29 | Audit Results
0
1000
2000
3000
4000
5000
0
20
40
60
80
100
120
7/21/2021 7/21/2022 7/21/2023SubmittedIssuedBacklog
These firms undergo a thorough approval process to ensure they meet the city’s
qualifications and adhere to local codes and standards. This model allows applicants to
select an approved private agency to expedite their permit review and/or conduct
inspections while ensuring that the municipality retains oversight and control over
compliance and enforcement.
These two models demonstrate the different levels of delegation and oversight that can be
applied, providing municipalities with the flexibility to balance efficiency with control and
enforcement.
Without a scalable solution, backlogs become routine, eventually leading to the need for
more full-time staff as demand grows. By adjusting staffing to match baseline demand,
third-party review services can provide temporary support during peak periods, helping to
manage backlogs and ensure timely processing. This approach offers flexibility to handle
fluctuations in application volume without permanently increasing staff levels.
The “backlog” refers to accumulating permit applications that have not yet been reviewed or
approved due to high volume, staffing limitations, or other delays. It represents the number
of pending permits awaiting processing.
Figure 2.3: Difference Between Applications Submitted vs. Processed and Backlog - Over Time. Data extracted from EPIC
Analyzed Office of the County Auditor
Permit
Dashboard
30 | Audit Results
Figure 2.3 shows the daily net difference between applications submitted by customers
(purple bars) and permits issued by staff (blue bars). Only a purple or blue bar is shown for
each date, reflecting the net outcome of submitted applications and processed permits. The
left axis represents the number of applications submitted (positive values) or permits
processed (negative values).
The yellow line represents the cumulative backlog over the audit period, which generally
trends upward and is shown on the right secondary axis. From earliest to latest, the x-axis
represents the audit period from July 26, 2021, to March 31, 2024.
Our analysis indicates that, on average, 16 applications were submitted daily, while staff
processed 12 applications per day, resulting in a persistent backlog. This issue was further
exacerbated by 26 significant surges in application submissions, where daily uploads
exceeded the usual daily average by over sevenfold.
Technical outages and software downtimes prevented BD from conducting meaningful
reviews, hampering operations and contributing to the backlog. Surges and downtime
combined have a significant impact on processing delays for applicants.
Artificial Intelligence (AI).
Municipalities can use technology as a scalable solution to address the growing permitting
process demands without increasing human resources. AI refers to applying advanced
computational systems that utilize machine learning, natural language processing, and data
analytics to streamline and enhance the evaluation of construction plans and permit
applications. AI is one tool that should enhance efficiency and accuracy and provide
scalability while ensuring compliance with regulations to increase the capacity of permit
processing workflows.
BD currently uses Bluebeam Revu, a plan review software that assists in identifying errors
and inconsistencies in submitted building plans. While this software supports accurate
reviews, the rapid evolution of additional AI-powered tools offers opportunities to expand
and optimize the permitting process even further.
Emerging technologies can complement existing systems by automating a broader range of
tasks, such as advanced application error detection, predictive analysis of potential code
violations, and streamlined workflows for applicants and reviewers. AI can also simplify
complex zoning and code research, enabling faster and more precise determinations, which
are not fully addressed by current solutions. These advancements allow reviewers to focus
on higher-value tasks, such as critical decision-making and policy alignment, rather than
repetitive administrative tasks.
31 | Audit Results
BD can reduce processing times, alleviate backlogs, and optimize resource allocation by
integrating these tools alongside existing platforms. Given AI's dynamic and evolving nature,
agencies must remain proactive in monitoring advancements and identifying integrations
that address specific operational needs. Leveraging evolving solutions alongside current
tools can ensure compliance, improve service quality, and better meet the growing
demands of permitting processes.
Conclusions.
The persistent delays and backlogs in the permitting system are driven by several
conditions: high application volume, resource constraints, and the lack of scalable
solutions. Key factors contributing to these challenges include the disproportionate
allocation of resources to low-risk applications, limited automation in the review process,
and the absence of mechanisms like self-certification and third-party reviews to manage
demand surges effectively. These conditions emphasize the importance of reducing
application volume and increasing processing capacity to alleviate backlogs and improve
the user experience.
32 | Audit Results
To Reduce Application Volume
We make the following recommendations
FINDING 1: The Volume of Applications Contributes to Delays
Cause of the Condition
1. The volume of applications submitted for permits consistently outpaces the
division's processing capacity.
2. A substantial portion of applications consists of rooftop photovoltaic (PV) systems
(25%), which consume division resources despite being low-risk and fast to
process.
3. Intake and plan review team members without professional licenses evaluate
submissions prepared by licensed design professionals.
4. Sudden and unpredictable application surges and software downtime disrupt
normal operations and strain division resources.
5. The division does not have scalable solutions, such as third-party review services,
to effectively manage surges in permit applications.
6. Low-risk and low-complexity applications that could be exempted are being
reviewed.
7. BD is hesitant to adopt a self-certification program for licensed design
professionals.
8. The current permitting process relies on limited automation, with existing tools
providing only basic capabilities in plan reviews.
Effect of the Condition
1. Persistent backlogs in permit processing result in extended applicant delays,
impacting project timelines and increasing user dissatisfaction.
2. Allocating resources to review low-risk applications, such as PV systems, limits
the division’s ability to focus on complex projects requiring greater attention.
3. Division staff making independent assessments of licensed design professionals’
work without sufficient training exposes the County to potential liability and
inefficiencies.
4. The operational disruptions from surges in applications and software downtime
result in staff resources being stretched thin, leading to increased workloads and
difficulty maintaining efficient processing.
5. The lack of scalable solutions contributes to prolonged delays in application
processing, further escalating the backlog.
6. Reviewing low-risk and low-complexity applications that could be exempted
diverts resources from processing more complex projects, contributing to
backlogs and delays.
33 | Audit Results
7. The absence of self-certification options for standard residential designs restricts
processing efficiency, leaving the entirety of application volume dependent on
departmental review.
8. Limited automation leads to slower workload management and contributes to
delays.
Recommendation 1
Exempt Qualified Low-Risk Applications.
Evaluate low-risk, low-impact applications (i.e., PV, solar water heater, water tanks,
fences, and walls) to identify opportunities to increase exemptions. The goal is to reduce
application volume, increase departmental capacity, and reallocate staff resources to
focus on more complex applications.
Recommendation 2
Implement Self-Certification and Provide Public Duty Doctrine Training.
Establish a self-certification program for licensed design professionals to certify standard
residential designs, reserving engineering staff for more complex reviews. This initiative
aims to expedite processing, improve efficiency, and reduce backlogs. Support the
program with regular Public Duty Doctrine training to clarify staff roles in verifying
submissions rather than independently reassessing certified work.
Recommendation 3a
Pilot Third-Party Review Services During Peak Periods.
Pilot a program using third-party plan review services as needed, addressing
unpredictable surges that exceed baseline capacity. Scalable solutions seek to minimize
backlogs without needing long-term staffing increases while ensuring consistent
processing times.
Recommendation 3b
Enhance AI Integration in Plan Review Processes.
Explore opportunities to integrate advanced AI-powered tools into plan review processes
to augment existing capabilities.
Elements include, but are not limited to:
• Automating error detection, discrepancies, or irregularities
• Identifying code compliance issues
• Simplifying zoning research
County of Hawaiʻi Of�ice of the County Auditor
Chapter 2: Audit Results
Processing Time
34 | Audit Results
Audit Activity.
To evaluate the efficiency of processing times in the permitting system, we:
• Analyzed EPIC-generated datasets from July 26, 2021, through March 31, 2024. This
included 15,575 permits, with an estimated valuation of $ 3,366,687,5588
• Interviewed staff and those charged with governance
• Reviewed applicable Administrative Rules, guides, and other written guidance
• Reviewed “Tinner Report” recommendations
• Attended the seminar, “Seven Low-Cost Ways to Speed Up Permitting in Hawaiʻi”
• Researched Lean Six Sigma for Service principles
Another obstacle affecting permits is processing time. The time it takes to process permits
impacts project timelines, business operations, and public services. Reducing processing
time improves efficiency and helps meet construction, development, or regulatory
compliance deadlines.
Application Processing Time.
We analyzed the time involved in the permit process to evaluate the system's overall
efficiency. By understanding time factors, the division can pinpoint delays, bottlenecks, or
inefficiencies that hinder progress. Metrics, including lead, cycle, and processing times,
provide distinct insights into process performance.
• Lead time measures the total duration from application submission to permit
issuance, offering a view of the applicant’s overall experience and the predictability
of the process.
• Cycle time focuses on the time taken to complete major stages within the process,
highlighting the Division’s internal efficiency at the stage level.
• Processing time drills deeper into individual activities within each stage, helping to
pinpoint specific tasks and activities that contribute to delays.
Lean Six Sigma, for the service industry, is a methodology that combines Lean's focus on
eliminating waste and improving process flow with Six Sigma's emphasis on reducing
variation and improving quality.
Lean Six Sigma for Service emphasizes the importance of concurrent monitoring metrics to
develop a comprehensive understanding of the permitting process. It accounts for the
complexities inherent in permitting, such as variations in application types, procedural
inconsistencies, or external factors impacting timelines. By addressing these complexities,
BD can implement targeted improvements that enhance internal productivity while
improving transparency, consistency, and the overall user experience.
8 Office of the County Auditor Permit Dashboard. https://www.hawaiicounty.gov/our-county/legislative/office-of-the-county-
auditor/audit-reports. Data provided by Building Division. Compiled Office of the County Auditor.
35 | Audit Results
Figure 3: Lean Six Sigma for Service Industry
Figure 3: Lean Six Sigma for Service Industry. Compiled Office of the County Auditor, visual not to drawn to scale
Three Types of Durations.
• Lead Time represents the total duration from application submission to permit issuance,
covering all stages and delays, including any time the application spends idle with the
division or with the applicant for resubmissions. Lead time is important for assessing the
overall user experience and the predictability of the permitting processing from start to
finish.
• Cycle Time represents the total duration a permit spends within each main stage of the
process, from when it enters a stage (such as intake, land use, multi-agency review, or
out-processing) to when it exits that stage and moves to the next. Cycle time captures
the entire span of a permit’s progress within each major stage, offering an overview of the
efficiency of each stage.
While cycle time can provide valuable insights into internal productivity, it must be
measured correctly. BD pauses the clock when applications are returned to the
customer for corrections or resubmittal, which affects the measurement. However,
delays may be caused by unclear or missing instructional materials, inconsistent
guidance, or overly complex requirements from BD, as well as misunderstandings or
incomplete submissions from the customer.
While it’s rational to discount time spent with the customer outside the department’s
control, tracking and analyzing these interactions is still critical to understanding delays
and making informed improvements. By measuring this time, BD can reduce the duration
and frequency of returned applications to the customer.
• Processing Time refers to the duration spent on individual activities within each stage of
the permitting process, such as completing forms, reviewing checklists, and conducting
specific compliance tasks. Analyzing processing time at this activity level makes it
possible to identify where time is being dedicated.
LEAD TIME
APPLICATION
SUBMITTED
APPLICATION
ASSIGNED
Stages
CYCLE TIME
Intake Land Use Multi-Agency Out Processing
TASK PROCESSING TIMES
REVIEW
COMPLETED
PERMIT
ISSUED
Issuance
36 | Audit Results
During the audit period, BD focused on cycle time, when applications are assigned and
actively being worked on. However, limiting the focus may obscure factors that impact the
overall lead time. For instance, the time at the beginning, when applications are submitted
and awaiting initial assignment, and at the end, after reviews have been completed and the
permit is awaiting issuance, are not fully captured in the cycle time. These periods
contribute significantly to the total lead time and should be considered in any process
efficiency analysis. Subsequently, in April 2024, BD began monitoring lead time during the
audit.
Additionally, BD uses averages to assess its performance through stages. While averages
can be a helpful metric, they can mask significant variability. For example, if four permits
take 25, 35, 35, and 100 days to issue, BD may report an average issuance time of 48.7 days.
While this might reflect a positive outcome for the first three applicants, the final applicant’s
experience is markedly different, conflicting with performance reports.
Variability among time intervals can reveal areas where improvements are necessary. We
examined the stages in the application process from a perspective of time and an analysis
of the first pass rate (the percentage of applications that are completed correctly and
approved without requiring corrections or resubmittal. It reflects the efficiency and
accuracy of the initial attempt), the minimum, maximum, and average number of reviews
and days at each review stage, along with common reasons for rejections.
Figure 3.1: 15,575 Applications Upload to Assignment.
Figure 3.1: Applications Upload to Assignment. Data extracted from EPIC, compiled Office of the County Auditor
37 | Audit Results
Figure 3.1 shows the time between permit uploads to the EPIC portal and their selection for
review. The system allows for application submissions without payment, and staff may
begin reviews after payment is received.
Although queue times have generally decreased, Figure 3.1 highlights significant variability
in assignment times. For example, on November 28, 2023, 17 applications were uploaded,
with assignment times ranging from same-day processing (0 days) to 111 days (March 18,
2023). This inconsistency in assignment times reflects inefficiencies in the assignment
process that require resolution. On average, applications spend approximately 37 days in
the queue before assignment.
During the audit period, BD did not account for initial wait times in its performance
calculations, leading to a disconnect between reported performance and user experience.
Subsequently, this has been corrected, and initial wait times are now included in
performance assessments. Addressing missing or incomplete documentation earlier in the
process should reduce queue times and improve user experience. BD also reported that
wait times caused by pending customer action outside their control contribute to delays.
Management directed staff to prioritize older permit numbers during the audit period, but
the permitting software did not effectively enforce this directive. Additionally, periodic shifts
in priorities to focus on specific types of permits have introduced inconsistencies. When
the queue is not cleared before shifting priorities, incomplete permits may remain inactive
for extended periods. These delays compound when attention returns to the original
category, as older permits may become buried within the queue.
First-in, first-out is a processing approach where tasks or items are handled in the exact
order they are received, ensuring that the oldest submissions are addressed first. This
method promotes fairness, consistency, and efficiency by preventing newer tasks from
being prioritized over older ones unless exceptions are explicitly defined.
Conclusion.
The time analysis of the upload stage revealed significant variability in assignment,
prioritization, and queue management. Improvements have been and continue to be made.
However, until early intervention designed to cut the wait time is implemented and date-
driven assignments are enforced through permissions or are strictly monitored and enforced
by management, BD will continue to struggle to increase user satisfaction. Findings and
recommendations aim to address these challenges and provide actionable steps for
improvement.
38 | Audit Results
To Improve Processing Efficiencies & Reduce Processing Time at Upload Stage
We make the following recommendations
FINDING 2: The Permit System Launched Prematurely Before Full Configuration and
Optimization
Cause of the Condition
1. BD lacked a dedicated pre-screening function to verify application completeness
early in the process, resulting in lost time for the customer.
2. BD’s focus on cycle time overlooks causes for delays, while manual self-
assignment of permits lacked automated prioritization or date-driven protocols.
Effect of the Condition
1. Applications with missing or incomplete documents are inevitably returned after
being assigned, resulting in lost time that could have been avoided if applicants
had been notified immediately, unnecessarily prolonging application timelines.
2. Inconsistent processing workflows lead to inequitable delays among permits.
Recommendation 4:
Dedicate a Pre-Screening Function.
Establish a dedicated pre-screening process to verify application completeness before
assignment to an intake clerk. This function should identify and request missing or
incomplete documents, proactively address common errors to improve first-attempt
approvals, and reduce subsequent errors and delays.
Recommendation 5:
Enforce Ascending Date-Driven Priority Protocol.
Assign permits in ascending order based on the oldest dates, ensuring that older
applications and submittals, including those requiring applicant action, are processed
first to prevent out-of-order selections. Exceptions should be made through direct
management assignments. Adopting this protocol could reduce variances and promote
consistent workflow.
39 | Audit Results
Stage 2: – Intake Review*9.
When applications are assigned, they begin with an Intake Review. During this stage, an
intake team member verifies the application for accuracy and completeness.
Intake reviews typically range from a few minutes to several hours, depending on the
complexity.
a. First Pass Rate: 79% Approval, 21% Rejected
b. Number of Reviews: 9 Maximum, 1 Minimum,1 Average
c. Days at Review: 263 Maximum, 0 Minimum, 5 Average
In addition to the overall approval and rejection percentages, it’s important to understand
how often customers must
resubmit during the process.
Applicants incur costs for returns
and resubmittals under Hawai‘i
County Code §5-7-1 (b). The code
specifies: “No additional plan
review fee is assessed for a second
submittal. Plan review fees for
subsequent submittals shall be:
$250 for a third submittal, $500 for a
fourth submittal, and $1,000 for
each additional submittal.” Fees
are not assessed for intake errors.
Figure 3.2 The vertical axis represents
the number of times an application was
reviewed at intake. The horizontal axis
shows how many applications from the population underwent a review. As an example,
2,329 applications were reviewed twice at the intake stage.
Reviewers noted common reasons for rejection:
Missing or Incomplete Information.
• Missing Tax Map Key (TMK) numbers
• Incomplete site plans (e.g., missing water sources, septic/cesspool systems, or
solar panel locations)
9 *Auditor Note: At Intake stage, we identified at least 20 instances where the assigned date was a date after the completion date, these
discrepancies were treated as zero.
Figure 3.2: Number of Resubmittal at Intake, data extracted from EPIC
Analyzed Office of the County Auditor
2329
491
144
33
10
4
0 500 1000 1500 2000 2500
2
3
4
5
6
7
Permits
No
o
f
T
i
m
e
s
Instances
40 | Audit Results
• Missing professional stamps, signatures, or required statements from licensed
architects/engineers
• Omitted documentation, such as:
o American Plywood Association (APA) structural calculations
o Code analysis or IECC compliance details
Improper Labeling and Formatting.
• Improperly labeled dimensions or plans marked "Not for Construction"
• Incomplete or improperly formatted PDFs
• Plans with less than three minor deviations proceed, while plans that do not meet
the latest standards adopted (IRC, IBC, NEC, and IECC) are returned for corrections
Project-Specific Requirements.
• Missing stamped electrical plans for systems exceeding 200 amps
• Missing plumbing plans for properties with four or more bathrooms
• Omitted detailed demolition site plans, as required for certain projects
Documentation Errors.
• Incomplete, outdated, or unsigned property owner and project declaration forms.
• Mismatched information with real property tax records
• Missing verification documents for authorized signatories (e.g., LLC or trust
documentation)
Failure to Address Corrections.
• Prior review corrections not addressed
• Missing detailed response letters explaining how corrections were resolved
Special Approvals.
• Missing required approvals, such as:
o Solar water heater variances
o State Department of Health wastewater system approvals
o Hawaiian Homelands letters (where applicable)
• Variance requests lacking justification or completeness
Errors During Resubmission.
• Duplicate permit submissions
• Unreadable file uploads
• Failure to use the EPIC system’s resubmittal features correctly
Conclusions.
Analysis of the intake review stage reveals rejections caused by incomplete applications,
outdated documentation requirements, and underutilized technology. Rejections delay the
review process and impose additional costs on applicants. Addressing these conditions
obligates BD to provide information that gives applicants a strong understanding of
requirements, leverage EPIC system features, and employ validation tools to reduce errors
during initial submissions. Additionally, tracking how applications are progressing error-
free enables data-driven process improvements.
41 | Audit Results
To Improve Processing Efficiencies and Reduce Days at Intake Stage
We make the following recommendations
FINDING 2: The Permit System Launched Prematurely Before Full Configuration and
Optimization
Cause of the Condition
1. Applications are often incomplete or incorrect due to applicants’ lack of
understanding, the complexity of the submission requirements, and the EPIC
system configuration.
2. The intake review process underutilizes real-time validation tools to identify
incomplete submissions immediately.
3. Documentation requirements are confusing and not updated when processes
change.
4. Performance metrics for monitoring the first-pass rate are not established
Effect of the Condition
1. A significant portion of applications (21%) is rejected at intake, on first pass,
requiring multiple resubmissions, prolonging the overall process.
2. Applicants are frequently required to resubmit, leading to delays and frustration.
3. Rejections due to common errors and persistent issues with submissions, along
with inconsistent application quality, increase the workload for both applicants
and staff
4. Without first-pass rate monitoring, the division cannot identify and address
systemic issues, leading to continued inefficiencies and high rates of follow-ups.
Recommedation 6
Strengthening Customer Education and Outreach.
Conduct periodic training workshops, either in person or virtual, for applicants and staff
to ensure expectations are communicated and understood by those who interact with the
system. Pre-recorded training videos should be periodically updated as operations
change.
Recommedation 7
Reduce Instances of Resubmissions.
Leverage EPIC system features to implement real-time validation prompts for incomplete
submissions, and assistance within the system’s limitations may include but is not limited
to tooltips, pop-ups, help icons, chatbots, etc.
Recommedation 8
Monitor and Evaluate First-Pass Rates.
Use established metrics to increase the first-pass rate of applications and analyze trends
to identify and address recurring issues. Use this data to refine the intake process
continually.
42 | Audit Results
Stage 3 – Land Use Review.
After intake approval, applications are forwarded to the Planning Department for land use
review. At this stage, the land use reviewer verifies the street address and checks the
application for applicable zoning or land use issues. If issues are discovered, applicants are
emailed a plan review comment letter, and the application is returned for correction. If
approved, it is marked as completed and awaits multi-agency assignment for further review.
Land use review is not required for electrical, plumbing, solar water heaters, or regulatory
inspections.
Review time generally ranges from one to three days.
a. First Pass Rate: 89% Approval, 11% Rejected
b. Number of Reviews: 7 Maximum, 1 Minimum, 1 Average
c. Days at Review: 366 Maximum, 0 Minimum, 6 Average
Figure 3.3 shows the frequency of
application re-reviews at the land
use review stage. The vertical axis
represents the number of times an
application was reviewed. The
horizontal axis shows how many
applications from the population
were required to undergo a review.
Reviewers noted common
reasons for rejection:
Special Management Area
(SMA) Considerations.
• Applications failing to
account for Special Management Area requirements
Site Plan Revisions.
• Blurred or missing dimensions on submitted site plans
Temporary Structures.
• Proposed temporary structures in zones where such structures are not permitted
Zoning and Setback Compliance.
• Non-compliance with zoning and setback requirements
Conclusions.
The land use review stage appeared to function efficiently during the audit period, with a high
first-pass approval rate and a relatively short average review time. While some applications
were returned for corrections, this stage is not a barrier and facilitates the timely progression
of applications to subsequent reviews.
Figure 3.3: Land Use Re-Evaluation, data extracted from EPIC
compiled Office of the County Auditor
835
258
97
25
9
2
1
0 100 200 300 400 500 600 700 800 900
2
3
4
5
6
7
8
Permits
No
. of
T
i
m
e
s
Instances
43 | Audit Results
Stage 4 – Multi-Agency Review.*10
The multi-agency review stages represent the most extensive and time-consuming portion
of the active permit processing workflow. During this stage, applications are routed
simultaneously to relevant agencies based on a predetermined workflow tailored to the
specific permit type. Depending on the type, up to ten different agencies may be involved in
reviews.
Concurrent reviews ensure that each agency evaluates the application for compliance
within its area of jurisdiction while reducing overall processing time and minimizing delays
caused by sequential review workflows.
Electrical Review.
An electrical plan review ensures that the electrical systems in construction projects comply
with the applicable 2020 National Electrical Code (NEC) and the 2018 International Energy
Conservation Code (IECC) standards. The primary objective is identifying and addressing
potential hazards or noncompliance issues before construction begins.
The reviewer assesses submitted plans and specifications for completeness and
compliance. This includes:
• Plan Verification: Ensuring signed and sealed plans accurately detail the scope of
electrical work
10 *Auditor Note: We omitted – Historic List Check, HLC(33, 100% not required), SHPD(2)
Figure 3.4: Plan Review Room from EPIC system
44 | Audit Results
• Equipment Identification: Confirming proper labeling of electrical equipment for
clear identification
• Lighting and Power Plans: Reviewing floor plans to verify the accuracy of circuit,
conduit, wiring sizes, and exterior lighting
• Emergency Systems: Checking placement and power supply for exit signs and
emergency lighting. The reviewer also evaluates panelboard and lighting fixture
schedules for system capacity and intended use, while symbol keys and diagrams
clarify technical aspects. Specifications are examined to confirm that materials and
installations, such as conduit, wiring, grounding, and transformers, meet code
requirements.
Work assignments are divided into residential and non-residential reviews. Reviewers also
handle phone, email, and in-person inquiries, adding to their daily workload. The time
required for a review depends on the project's size and complexity.
One significant challenge noted by staff is the high
volume of photovoltaic (PV) system permits,
particularly those under 10 kW. These projects require
inspection permits but not an electrical plan
review. However, they appear in project
queues, artificially increasing the workload.
The time required for an electrical review varies depending on the project’s scope and
complexity, with larger projects requiring more time and smaller or simpler ones being
reviewed more quickly.
a. First Pass Rate: 96% approval, 4% Rejected
b. Number of Reviews: 5 Maximum, 1 Minimum, 1 Average
c. Days at Review: 139 Maximum, 1 Minimum, 3.4 Average
Reviewers noted common reasons for rejection:
• General electrical plan and compliance requirements
• Electrical systems and scope
• Code references and legal compliance
Figure 3.5: Example of PV stamp used by BD from EPIC system
45 | Audit Results
Mechanical/Plumbing Review.
The mechanical and plumbing review focuses on verifying that designs adhere to safety and
health requirements, ensuring the systems function while remaining compliant with
applicable codes.
Residential Plumbing Review.
Residential plumbing review is limited to projects with four or more bathrooms per HCC
§5-4-3(i). These reviews focus on the complexities of larger plumbing systems,
including:
• Waste and venting systems
• Correct sizing and placement of cleanouts
• Water supply and pressure management
If air conditioning is included, the review ensures compliance with equipment
specifications, ducting, condensate disposal, and energy code requirements.
Non-Residential Applications.
Non-residential reviews vary widely in complexity, from simple tenant improvements to
large-scale projects like hospitals, restaurants, and hotels. Specific considerations
include:
• Plumbing Systems (e.g., restaurants):
o Grease waste isolation
o Grease interceptor sizing
o Trap protection, indirect waste, and cross-connection systems
• Mechanical Systems
o Cooking hoods, ventilation, and fire suppression systems
o HVAC components, ducting, and condensate management
o Required outside air, fire dampers, and system separation compliance
Streamlining Opportunities.
Staff noted opportunities to streamline the mechanical and plumbing review process by
filtering out projects that do not require review. For example, residential plans with fewer
than four bathrooms appear in the work queue, requiring extra time to mark as "not
required." This unnecessary step delays processing.
Challenges also arise from resubmissions. Management explained that the staff did not
understand the Cloud+Delta convention. Projects failing at any multi-agency review stage
are sent back to all reviewers, including those who previously approved them. This creates
redundant reviews, which are time-consuming and resource-intensive. Automation to
exclude unnecessary projects and resubmissions should significantly enhance efficiency.
46 | Audit Results
Reviewer time varies based on project complexity and plan quality. Typically, residential
reviews take 10 to 20 minutes, smaller non-residential projects take 30 to 45 minutes, and
larger, more complex plans may take an hour or longer.
a. First Pass Rate: 92% Approval, 8% Rejected
b. Number of Reviews: 6 Maximum, 1 Minimum, 1 Average
c. Days at Review: 135 Maximum, 1 Minimum, 5.7 Average
Reviewers noted common reasons for rejection:
• Missing HVAC plans, plumbing plans, and specifications
• Noncompliance with outdoor plumbing fixtures
• Propane gas system requirements
• Missing water and gas system drawings
• General ordinance compliance
• Plan corrections, missing details, and miscellaneous compliance issues
Structural Review.
The review ensures construction projects comply with applicable safety and design
standards to prevent structural failure. This includes verifying that designs provide sufficient
strength, stiffness, and proper assembly. The review focuses on code compliance and the
integrity of the structural system while identifying plans that may need more precise
documentation. Special attention is given to Hawai‘i County’s unique seismic activity and
wind load requirements.
Projects in areas with wind speeds exceeding 140 mph require detailed analysis to ensure
they meet structural requirements. However, projects in areas with wind speeds below 140
mph or those with slab-on-grade designs generally do not require such reviews. These
applications are manually marked as "not required" for review, which artificially increases
the workload. When these applications are returned for resubmission at any stage of the
multi-agency review process, all reviewers— including those who previously approved
them— receive the applications again. While these applications are manually passed, the
process causes delays as team members must sift through them to determine which ones
require review and which can be approved without further scrutiny.
Reviewer time ranged from a few minutes to a few days.
a. First Pass Rate: 80% Approval, 20% Rejected
b. Number of Reviews: 5 Maximum, 1 Minimum, 1 Average
c. Days at Review: 242 Maximum, 1 Minimum, 9 Average
Reviewers noted common reasons for rejection:
• Missing or incomplete structural design
• Review requirements
47 | Audit Results
Engineering Review. (DPW - Engineering Division) (*Auditor note includes “Eng West” in dataset)
The Engineering Division evaluates permit submissions for compliance with regulations
concerning grading, floodplain management, and drainage requirements. This includes
reviewing site plans for accurate property identification, ensuring grading and fill slopes
adhere to Hawai‘i County Code Chapter 10, and verifying compliance with floodplain
requirements, such as delineating flood zone boundaries and providing base flood elevation
documentation.
Submissions must address drainage structures, retaining walls, and compliance with
setback requirements. Plans are checked for consistency with approved reports and
calculations. Additionally, permits require confirmation of grading permits, floodplain
management certifications, and alignment with civil engineering standards for design and
safety.
Reviewer time generally ranges from 10 to 15 minutes to an hour to review.
a. First Pass Rate: 99% Approval, 1% Rejected
b. Number of Reviews: 5 Maximum, 1 Minimum, 1 Average
c. Days at Review: 241 Maximum, 1 Minimum, 4.4 Average
Reviewers noted common reasons for rejection:
Floodplain Management Requirements.
• Applications failed to comply with floodplain management standards
• Missing documentation, such as flood elevation certificates or floodproofing designs
• Failure to indicate or accurately map flood zone boundaries on site plans
Grading and Drainage.
• Non-adherence to slope, setback, and drainage structure standards
• Poor drainage design leading to potential water flow or erosion issues
• Inadequate plans for stormwater management and water runoff control
Site Plan Discrepancies.
• Inconsistencies between site plans and approved reports
• Mismatched or incomplete property details, such as incorrect lot dimensions or
boundaries
Driveway and Encroachment Issues.
• Violations in driveway design, such as improper widths, slopes, or material
specifications
• Structural encroachments into County rights-of-way or easements
Documentation Errors or Omissions.
• Missing or incomplete valuation breakdowns required for review
• Lack of supporting reports, such as geotechnical, drainage, or environmental impact
assessments
48 | Audit Results
Building Code Review (Residential).
Building plan reviews encompass assessing life safety requirements, prescriptive structural
design, and compliance with various regulatory frameworks, including the Construction
Administrative Code (Chapter 5) and other applicable codes. These reviews ensure all
submitted plans adhere to structural, design, and safety standards.
For residential plan reviews, the focus is on verifying the completeness of submissions,
ensuring that resubmittals adequately address correction items, and confirming
compliance with relevant codes. Plans must be signed and stamped by licensed
professionals when required, and specific calculations, such as those for brace wall designs
or wind load compliance, must be included where applicable.
Specific guidance can lead to confusion, particularly regarding differences between the
County Code and state-adopted building codes. For instance, while the County Code
Chapter 5A refers to the 2006 International Building Code (IBC), the state has adopted the
2018 edition with amendments. In this example, the design professionals could mistakenly
assume they only need to comply with the older 2006 standards, which could lead to serious
noncompliance issues when the state’s newer standards are enforced.
Subsequently, management reported they updated applicable references to the 2006 HCC
with the state-adopted code and are awaiting state adoption of 2021 and 2024.
Furthermore, any preapproved home designs become outdated when the county updates
the newer IBC versions. As a result, developers or homeowners may face costly delays or
redesigns to meet current standards. This introduces financial risks, legal exposure, and
significant rework, particularly for those unfamiliar with the code's evolution or the
implications of its amendments.
Separately, inconsistencies in terminology create confusion, particularly when similar
terms are used interchangeably. For example, the status designations “requires applicant
action” and “requires resubmittal” are often treated as synonymous by staff. This overlap
can lead to the mis-designation of applications, skewing statistical data and performance
reports. As a result, the tracking of application progress becomes inaccurate, making it
difficult to assess processing times and overall efficiency.
Review time varies depending on the complexity of the project and/or the completeness of
the plans, ranging from 2 hours to 2 days while also performing other related duties.
a. First Pass Rate: 77% Approval, 23% Rejected
b. Number of Reviews: 7 Maximum, 1 Minimum, 1 Average
c. Days at Review: 285 Maximum, 1 Minimum, 26 Average
49 | Audit Results
Reviewers noted common reasons for rejection:
• Document submission and format requirements, correction items, and resubmission
instructions
• Structural and engineering requirements
• Building code compliance
• Plan corrections for specific trades
• Additional documentation requirements
• Other miscellaneous comments
Plan Reviews Non-Residential.
Non-residential reviews are very similar to residential reviews but focus on commercial
applications, which are generally more complex than residential projects.
Review time varies depending on the complexity of the project and/or the completeness of
the plans, ranging from 2 hours or up to 2 days while also performing other related duties.
a. First Pass Rate: 64% Approval, 36% Rejected
b. Number of Reviews: 6 Maximum, 1 Minimum, 2 Average
c. Days at Review: 277 Maximum, 1 Minimum, 31 Average
Reviewers noted common reasons for rejection:
• Revisions and resubmissions required
• Compliance with specific requirements
• Variances and special approvals
• Missing special inspection forms and certifications
• Unresolved corrections
• Other miscellaneous comments
County Sewer Access Review. (completed by the Department of Environmental
Management Wastewater Division (WWD))
Applications must include a request to perform work on the Public Sewer System Form and
a plot plan illustrating the intended connection. Plans must address conditions such as
proper sewer cleanouts, grease interceptor installations, or compliance with wastewater
pretreatment requirements. Submissions are reviewed for complete and accurate
documentation.
a. First Pass Rate: 84% Approval, 16% Rejected
b. Number of Reviews: 4 Maximum, 1 Minimum, 1 Average
c. Days at Review: 189 Maximum, 1 Minimum, 20 Average
Reviewers noted common reasons for rejection:
• Connection to public sewer system
• Incomplete forms
• Plot plan sketch requirements
50 | Audit Results
• Sewer engineering plans and approvals
• Inspection coordination with WWD
• Sewer disconnection
• Demolition
• Miscellaneous sewer-related comments
Septic System Review. (completed by the Department of Health, Wastewater Branch)
Evaluate applications for an Individual Wastewater System (IWS) prepared by licensed
engineers to verify compliance with design, capacity, and setback requirements. Oversees
the proper abandonment of cesspools, upgrades to septic systems, and wastewater
variances, ensuring adherence to environmental regulations.
Currently, one licensed engineer based in Kona is assigned to review all applications from
Kona but could also review applications from other parts of Hawaii Island. Applications from
Hilo are routed to Honolulu, where they are combined with applications from other
municipalities within the state. Natural disasters like the Lahaina Fire can shift priorities and
impact the review process. The Department of Health (DOH) staff estimates receiving up to
40 applications statewide per day, contributing to an approximate two-month backlog.
Additionally, applications outside of DOH’s purview, such as PV roof mount installations,
add to the delays by overwhelming the queue.
Reviews typically range from 15 to 20 minutes up to one day to complete.
a. First Pass Rate: 88% Approval, 12% Rejected
b. Number of Reviews: 5 Maximum, 1 Minimum, 1 Average
c. Days at Review: 208 Maximum, 1 Minimum, 12 Average
Reviewers noted common reasons for rejection:
• Wastewater capacity and bedroom count limitations
• DOH requirements for system design
• As-built drawings and site plan deficiencies
• Cesspool upgrade and replacement requirements
• Wastewater variances and compliance with environmental regulations
• Other miscellaneous comments
Department of Health Food Safety. (DOH-FS)
DOH-FS evaluates compliance with health and safety standards for food establishments,
mechanical ventilation systems, and demolition projects. Key documentation includes the
Food Establishment Plan Review Application for kitchen-related projects, Form 111 for
ventilation system designs, and the Notification of Demolition and Renovation for hazardous
materials projects.
11 Department of Health. Form 1 https://health.hawaii.gov/wastewater/files/2017/06/Form1.pdf Accessed: 12/30/24
51 | Audit Results
Reviews focus on ventilation and exhaust systems, proper sink placement, and compliance
with National Emission Standards for Hazardous Air Pollutants (NESHAP) in demolition
projects. Additionally, specialized approvals may be required from the Indoor Air and
Radiological Health Branch or the Food Safety Branch.
Review time depends on the applicant’s response to DOH-FS requirements.
a. First Pass Rate: 88% Approval, 12% Rejected
b. Number of Reviews: 4 Maximum, 1 Minimum, 1 Average
c. Days at Review: 155 Maximum, 1 Minimum, 8 Average
Reviewers noted common reasons for rejection:
• Food establishment plan review and permits
• Handwashing and utility sink requirements
• Notices of demolition and renovation
• Miscellaneous corrections and instructions
Fire Review. (completed by Hawai‘i Fire Department (HFD))
HFD reviews ensure compliance with the Hawai‘i State Fire Code, Chapter 17 of the Hawai‘i
County Code, and NFPA standards. Key areas evaluated include fire department access,
water supply, and fire protection systems. Access evaluations consider road width, surface,
slope, turning radius, building distance, vertical clearance, and obstructions. Water supply
checks include hydrant location, fire flow, and alternative sources.
Fire protection systems, such as alarms, sprinklers, standpipes, and suppression systems,
are assessed based on building size, occupancy type, construction type, and occupancy
load per the IBC. The required systems must adhere to NFPA standards and sprinkler plans.
Additional reviews cover specific occupancies like aircraft hangars, fuel farms, malls, and
hazardous materials, including fuel storage. Temporary structures require permits and fees.
The department collaborates with inspectors throughout the process for guidance and
compliance verification.
Review time generally ranges from two to three hours per plan to complete.
a. First Pass Rate: 83% Approval, 17% Rejected
b. Number of Reviews: 5 Maximum, 1 Minimum, 1 Average
c. Days at Review: 89 Maximum, 1 Minimum, 6.3 Average
Reviewers noted common reasons for rejection:
• Access and water supply requirements
• Contact details
• Inspector clarifications
52 | Audit Results
Conclusion.
During multi-agency reviews, applications take an
average of 49 days to navigate complex coordination,
with several systemic obstacles. Applications are often
rerouted back into review queues despite additional
filtering for DEM-WW and DOH, prior approvals,
creating redundant work and delaying final decisions.
The influx of unnecessary permits—classified as "not
required"—clogs review queues, diverting valuable
resources away from critical applications.
Confusion caused by inconsistent use of terms
disrupts the process, leading to
miscommunication between agencies and
applicants. Employees’ limited understanding of their peers’ responsibilities contributes to
fragmented coordination, duplicative efforts, and resource mismanagement. Some reviews
require significant human resources despite having a 99% approval rate, which raises
concern about their necessity and the overall benefit relative to the time invested.
Figure 3.6: Example of “Not Required” workflow
used by BD from EPIC system
53 | Audit Results
To Improve Processing Efficiencies and Reduce Days at Multi-Agency Stage
We make the following recommendations
FINDING 2: The Permit System Launched Prematurely Before Full Configuration and
Optimization
Cause of the Condition
1. Applications are redundantly routed back into review queues despite having
previously received approval.
2. Workflow management processes lack optimization.
3. Review queues are inundated with permits that are not required.
4. Similar terms are inconsistently applied.
5. Agencies lack awareness of other multi-agency tasks.
6. The necessity of some reviews raises concerns about the time vs. benefit due to
human resource requirements and high approval rates.
Effect of the Condition
1. When applications are returned to review queues, it prolongs the permitting
process, creates redundant work, and delays final approvals.
2. Inefficient workflow management results in extended processing times, reduced
capacity to handle submissions, and increased frustration for applicants.
3. The influx of unnecessary permits overwhelms review queues, diverting resources
and attention from critical applications.
4. Delays arise from errors in classification or interpretation.
5. Lack of understanding of all multiagency review steps leads to fragmented
coordination, duplicative efforts, and inefficiencies in the review process.
6. The resource-intensive nature of some reviews and high approval rates divert
resources from potentially higher-priority activities without significantly impacting
outcomes.
54 | Audit Results
Recommedation 9
Streamline Workflow Management.
Implement routing tools to ensure applications progress in a clear and sequential order,
appear only once when approved, and are routed only to the necessary parties based on
permit type.
Recommendation 10
Update Staff and Public Education Materials.
Review and update internal and external guidance to ensure definitions and their
associated usage are clearly communicated to both the workforce and to the public and
are applied consistently.
Recommendation 11
Consolidate Reviews.
Consolidate reviews and redeploy staff to value-added tasks.
Recommendation 12
Enhance Interagency Cooperation.
Ensure consistent processing by State agencies through a supplemental agreement.
Coordinate with state agencies to establish clear expectations for processing timelines,
priority allocation, and feedback.
The agreement should outline measurable production standards, such as defined
timeframes for reviews and prioritization criteria, to ensure consistency in processing
applications.
Additionally, the agreement should include mechanisms for regular collaboration and
periodic reviews to address balancing the workload across agencies and changing
priorities.
55 | Audit Results
Stage 5: Application Out Processing.
Once all multi-agency reviews are completed and approved, the application moves to out-
processing, where documentation is re-checked for accuracy and completeness.
Out processing takes 15-20 minutes and up to one day.
a. First Pass Rate: 95% Approval, 5% Rejected
b. Number of Reviews: 6 Maximum, 1 Minimum, 1 Average
c. Days at Review: 124 Maximum, 1 Minimum, 5 Average
Intake teams may review the same documentation multiple times, up to five times, at
different process stages.
Reviewers noted common reasons for rejection:
• Missing, incomplete, or incorrect project declaration forms
• Missing owner signature, plan submission and corrections, stamps, and
miscellaneous errors.
Conclusions.
The permitting process involves two critical quality control steps: Intake (front-end
completeness checks) and out-processing (back-end completeness checks). While these
steps ensure quality and accuracy, their combined implementation contributes to time
delays, creating a bottleneck in the overall process.
Front-End Completeness Checks: These are performed during intake to validate that
applications are complete and accurate before entering the review process. They help
prevent downstream errors by catching issues early.
Back-End Completeness Checks:
During out-processing, checks ensure all required approvals and conditions are met before
issuing a permit. This includes verifying contractor licenses to ensure they are valid
professional licenses before work begins. While each step has merit, the combined process
leads to duplicated efforts and wasted time.
For example:
• Front-end checks already ensure that applications entering the process are
complete, reducing the likelihood of errors that back-end checks would catch.
• Back-end checks repeat this validation, with little additional value when thorough
intake checks are performed.
Impact on Timeliness: This dual-check approach increases processing times and diverts
resources better utilized elsewhere. By introducing unnecessary layers of verification, the
system ultimately slows permit issuance.
56 | Audit Results
To Improve Processing Efficiencies and Reduce Days at Out Processing Stage
We make the following recommendations
FINDING 2: The Permit System Launched Prematurely Before Full Configuration and
Optimization
Cause of the Condition
The processing stage is a final review that duplicates completeness checks already
performed at earlier stages of the process.
Effect of the Condition
While the out-processing is designed to ensure accuracy and quality, it causes delays,
increases costs, and leads to unnecessary duplication of effort.
Recommedation 13
Automate Invoicing and Issue Provisional Permits for Construction Start.
Upon successful completion of the last multi-agency review, automate invoicing the
applicant and issuing a provisional permit to begin construction, and automate and/or
integrate outstanding fee collection before final inspection into the system.
57 | Audit Results
Stage 6 – Permit Issuance.
Finally, the application enters a waiting period before the permit is issued. During this time,
final fees are collected, and the applicant uploads the required Project Declaration Form if
it hasn’t already been submitted with the initial application. This step is largely outside BD's
control and depends on the applicant's action.
Figure 3.7 shows the number of days an application waits for a permit to be granted,
appearing from the earliest left-to-right. Average wait times were 30 days with persistent and
significant fluctuations. Permit issuance typically takes a few minutes to a few days. EPIC
system enables staff from the east and west offices to process applications from a shared
pool.
Figure 3.7: Issuance queue
Figure 3.7: Issuance queue, data extracted from EPIC, compiled Office of the County Auditor
To establish overall time limits and hold the review function accountable to maximum review
periods, the Grassroots Institute of Hawai‘i recommended that counties in Hawai‘i adopt
“shot clocks,” a practice used by other municipalities across the country. “Shot clocks” refer
to the set time government agencies have to issue or deny a permit application, with
penalties for missing deadlines. This approach would impose time constraints and
maximum timelines on permit reviews to accelerate processing. The legal framework to
support this is already in place under HRS §91-13.5 (a), which states:
“Unless otherwise provided by law, an agency shall adopt rules that specify a
maximum time period to adopt or deny a business or development-related
permit license or approval, provided that the application is not subject to
state-administered permit programs delegated, authorized, or approved
under federal law.”
58 | Audit Results
BD has also formalized time limits for permit reviews in its Rules of the Building Division
Governing the Enforcement of Codes and Regulations Part II, §2.2 General. Which
states:
“…Complete applications and supplemental data (i.e. plans, specifications,
and computations) for permits shall be submitted to the building official for
review and approval as required by each effective code or regulation. Each
permit/plan reviewer for each Code within the Building division shall have
thirty (30) days to review completed submittals. Should a reviewer of the
building division fail to take action within the time limitation, approval would
be automatic pursuant to the requirements of Hawai‘i Revised Statutes.”
However, despite the provisions in HRS §91-13.5 9(a) and the Building Division Code
Enforcement Rules §2.2, the EPIC system does not enforce this time limit.
Conclusion.
Average wait times often exceed 30 days, and permit issuance fluctuates greatly. While
some of these delays are outside the control of the Building Division, particularly during the
applicant's waiting period for final fees and documents, there are still opportunities to
improve efficiency. The lack of enforcement of time limits, despite established rules in HRS
§91-13.5 and the Building Division's regulations, contributes to unnecessary delays in permit
issuance. Implementing "shot clocks" or strict time constraints, along with more consistent
enforcement of existing deadlines, would help expedite the permit process, reduce costs for
applicants, and hold the review function accountable to its timelines. By enforcing these
rules and updating administrative guidelines, the Building Division can ensure timely permit
issuance and provide a smoother experience for applicants.
59 | Audit Results
To Improve Processing Efficiencies and Reduce Days at Permit Issuance
We make the following recommendations
FINDING 2: The Permit System Launched Prematurely Before Full Configuration and
Optimization
Cause of the Condition
The Building Division does not follow or enforce administrative rules regarding maximum
time limits.
Effect of the Condition
Permit applications are held up unnecessarily, adding to costs and delays for the
applicants.
Recommedation 14a
Enforce Consistent Timeframes for the Permit Evaluation Process.
BD enforces its rules to ensure it either meets its required deadlines or advances the
applications by default approval.
Recommendation 14b
Review and Update Administrative Rules to Establish Maximum Timelines for
Reviews.
Review and update its administrative rules to set maximum timelines for reviews that it
can reasonably adhere to.
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County of Hawaiʻi Of�ice of the County Auditor
Chapter 2: Audit Results
Complexity
60 | Audit Results
Audit Activity.
To identify obstacles in the permitting system, we:
• Analyzed EPIC-generated datasets from July 26, 2021, through March 31, 2024,
including 15,575 permits, with an estimated valuation of $ 3,366,687,55812
• Reviewed Hawai‘i Revised Statutes §489E-7 Legal recognition of electronic records,
electronic signatures, and electronic contracts
• Reviewed applicable Administrative Rules, guides, and other written guidance
• Reviewed the Hawai‘i County Code Chapter 5 Construction Administrative Code,
“Tinner Report,”13 and the Grassroots Institute of Hawai‘i Policy Brief14 (October 2024)
• Attended the seminar, “Seven Low-Cost Ways to Speed Up Permitting in Hawai‘i”
• Interviewed staff and those charged with governance
• Navigated the EPIC portal as an end-user
• Researched Lean Six Sigma for Service principles
• Benchmarked County of Phoenix, AZ, using the Energov portal
Another obstacle affecting permits is complexity. The more complex the permit
requirements are, the more resources are needed to review and approve them. Simplifying
complex procedures reduces errors, enhances consistency, and speeds up the overall
process.
Application Complexity Overview.
Lean Six Sigma for Service principles emphasize the importance of developing a holistic
understanding of processes to identify bottlenecks, inefficiencies, and variability at all levels
to reduce complexity, increase speed, and improve quality. Lean Six Sigma for Service is a
methodology that combines the principles of Lean (focuses on reducing waste and
improving efficiency) with Six Sigma (focuses on reducing variability and improving quality)
optimizing processes. It emphasizes a systematic, data-driven approach to understanding
and improving workflows, particularly in service-oriented environments.
The "Tinner Report" (Attachment A) recommended that BD hire an external consultant to
educate staff about lean process improvement. The consultant would document each step,
interaction, and workflow involved in the permit application process, from intake to
issuance. They would also evaluate whether each step is legally required or necessary and
eliminate unnecessary steps, potentially reducing workloads by 15 to 40 percent.
12 Office of the County Auditor Permit Dashboard. https://www.hawaiicounty.gov/our-county/legislative/office-of-the-county-
auditor/audit-reports. Data provided by Building Division. Compiled Office of the County Auditor.
13 James Tinner, “Consultant’s Report: COM 36.1 (2022-24)” https://records.hawaiicounty.gov/Weblink/0/doc/1049842/Page1.aspx.
Accessed 11-20-24
14 Grassroots Institute of Hawai‘i. Policy Brief, (October 2024), Seven low-cost ways to speed up permitting in Hawai‘i Expediting the
issuance of building permits is critical to making a dent in Hawaii’s housing crisis. https://www.grassrootinstitute.org/wp-
content/uploads/2023/12/241007_pb_permits.pdf. Accessed 11-20-24
61 | Audit Results
Management reported that staff were still learning the system and refining the one-permit
process during the Electronic Permitting System (EPL) rollout. Although the Mayor’s Office
selected a contractor with good intentions, their involvement became a distraction. At that
stage, the division’s priority was to get the system operational, and the added coordination
required for the consultant pulled focus from that effort. While engaging a consultant might
have been more effective before going live, their involvement during an unstructured
implementation offered limited value.
Although the division's capacity to implement broader process improvements was
constrained during this period, the recommendations offered—such as those from Tinner—
are still applicable.
Tinner recommended defining by ordinance what constitutes a complete permit application.
This would streamline the process by creating clear expectations and alignment between
the department and the applicant, reducing confusion and ensuring all required documents
are submitted upfront. BD’s goal is to issue Residential Building Permits within 60 calendar
days of submittal when applications are complete, as long as no corrections are needed.
We found.
Navigating the various educational materials is cumbersome. Material consists of the
Permit Application Checklist,15 Tips for a Successful Permit Application Intake,16 and a
library of forms.17 Despite BD’s efforts to clarify application requirements, end-users often
struggle to find the necessary information.
15 County of Hawai‘i DPW Building Division. “Permit Applicant Checklist”. Page 1 of 2.
https://records.hawaiicounty.gov/weblink/1/edoc/140083/BLG_Permit_Applicant_Checklist.pdf Accessed 1/2/25
16 County of Hawai‘i DPW Building Division. “Tips For a Successful Permit Application Intake”.
https://records.hawaiicounty.gov/weblink/1/edoc/140084/BLG_Tips_for_Successful_Permit_App.pdf Accessed 1/2/25
17 County of Hawai‘i DPW Building Division. “Building Forms”. https://hawaii-county-public-works-
hawaiicountygis.hub.arcgis.com/pages/blg-building-forms Accessed 1/2/25
62 | Audit Results
Figure 4: Permit Applicant Checklist
Figure 4: County of Hawai‘i DPW Building Division. Permit Applicant Checklist
https://records.hawaiicounty.gov/weblink/1/edoc/140083/BLG_Permit_Applicant_Checklist.pdf. Accessed: 1/2/25
63 | Audit Results
Overview of EPIC Seven-Step Permit Process.
After creating a user profile and selecting a permit type, the EPIC portal takes the user
through a seven-step process:
Step 1. Location
Figure 4.1: Step 1 “Location” from EPIC System
The application process begins with the selection of a project
location. Once identified, the location is added to the project, and
the system captures key details such as the project type, parcel
number, and address (if assigned). If there are no extenuating
conditions—such as the property being located in a Special
Management Area or flood zone, the applicant can continue to the
next step. However, additional compliance steps are required if such
conditions exist before the application can proceed.
We found.
Information captured at this step is not used to prefill other
data points or satisfy other steps later in the application. We
benchmarked the functionality and effectiveness of the County
of Hawaiʻi’s Energov portal by comparing workflows.
Maricopa County, AZ, replaced its Accela
Permitting System with Energov in June
2024. Maricopa has a robust mapping
service that uses the Environmental Systems Research Institute (“ESRI”) satellite overlay to
distinguish properties by zoning use type and districts visually.
Hawai‘i County GIS Energov Map
Figure 4.3: Hawai‘i County GIS Engergov
Figure 4.2: Example of “Type” based off TMK from EPIC system
64 | Audit Results
Maricopa County GIS Engergov Map
Figure 4.4: Maricopa County GIS Mapping Applications
The difference in mapping service sophistication highlights the potential to use more
advanced mapping to identify common errors early in the process.
Step 2. Type
Figure 4.5: Step 2 “Type” from EPIC system
In the “Type” screen, the applicant is asked to provide a detailed description, including a
valuation, materials, and labor list.
We found.
The current process of requiring detailed project descriptions is a Legacy system practice
that no longer serves its original purpose. Historically, BD staff developed specific
preferences for how project descriptions should be formatted and written. Guides instruct
employees to “enter a thorough description of work as you would be walking through the
structure.” However, this approach was developed when BD did not retain plans, and on-
site inspectors relied on detailed descriptions for guidance.
With the arrival of the electronic system, the ability to retain plans, and the requirement to
have site plans available, the value of continuing this practice no longer justifies time and
resources. Modernizing this process should lead to greater efficiency without compromising
the quality or accuracy of reviews. Contrary to the guidance provided to staff, applicant
instructions are vague. This results in applicant descriptions almost always being rewritten
by staff for new residential construction permits.
65 | Audit Results
Figure 4.6: Comparision of Customer vs. Staff Instructions
New Residential Construction Permit
EPIC Portal Instructions for Customer Written Instructions for Staff
New Residential Construction Permit
Please provide a description of your project
along with the valuation costs of all
materials, labor, etc…
Portal example, “Pacific Condos 1 of 15:
New Single-Family Dwelling, etc…”
Edit the description of work by clicking on
the pencil icon.
a. Using the plans, enter a thorough
description of work as you would be walking
through the structure. Your first sentence
should always start with (1-Permit),
followed by a summary of the work. Next,
you will describe all uses as shown on the
floor plan, including the bathroom, kitchen,
and laundry room fixtures in an orderly
manner as though you are walking through
the structure.
Example of description for a new dwelling:
(1-Permit) New 3-bedroom, 2-bathroom
single family dwelling with on-demand gas
water heater (approved solar variance
#xxxxxx-xx-25-10), concrete slab
foundation, 7'2" high galvanized steel water
tank, and septic system.
Open covered entry lanai into living
room/dining room/kitchen (refrigerator,
double compartment sink, range/oven),
bedroom #2, bedroom #3, bathroom #2
(lavatory, water closet and tub/shower
combo), master bedroom with walk in
closet and master bathroom (two
lavatories, water closet, shower stall and
separate jacuzzi tub). Attached two car
garage (overhead garage door) with open
utility area (washer, dryer, laundry tray) and
enclosed storage closet (OnDemand water
heater within).
Figure 4.6: EPIC Portal Instructions for Customers vs. Written Instructions for Staff for New Residential Construction Permit
Compliled Office of the County Auditor
66 | Audit Results
Step 3. Contacts
Figure 4.7: Step 3 “Contacts” from EPIC system
The “Contacts” screen is designed to
collect stakeholders associated with the
project, including owners, designers, and
professional trades. A “contact” refers to
an individual associated with a permit
authorized to access its details.
We Found.
The system does not sort contacts by
stakeholder type, making the step error-
prone because anyone with an EPIC
profile could be incorrectly categorized
as a contact or a trade professional.
Additionally, there is no validation to ensure that only qualified individuals appear under the
relevant trade categories. For example, when selecting 'plumbing' as a trade, the system
does not filter out unlicensed or inactive plumbers. This increases the risk of errors by
allowing contractors who may not be in good standing to be assigned to projects.
Without restrictions, applicants could designate themselves as a plumber and an
electrician, even if they only hold a license in one trade. Maintaining separate lists to ensure
accuracy and prevent misclassification is important.
Figure 4.8: Two examples of contact(s) from EPIC system
67 | Audit Results
Step 4. More Info
Figure 4.9: Step 4 “More Info” from EPIC system
The "More Info" screen is designed to collect additional details and varies according to
project type. Applicants are instructed to provide comprehensive project details to avoid
delays in permit approval.
We found.
Evaluating the screen's structure and data points highlights potential clarity, data validation,
and redundancy issues.
Tooltips and Help Icons.
A tooltip is a brief, context-specific message box that provides information when hovering
over a field, while a help icon offers more detailed guidance upon clicking or hovering.
Numerous data points lack explanation and leave casual users unsure what specific
information is being requested of them. Some examples that lack appropriate context:
• Declaration Exemption Number
• + Add Row
• Fire resistance ratings table
Automation.
In the Residential New Construction permit type, applicants must provide the "Pre-approved
House Package Number." Despite BD already possessing the preapproved plan information,
the portal still requires applicants to input it instead of auto-populating it or exempting
applicants from re-entering it.
Data Collection.
There is redundancy between information collected in the “Type,” “More info,” and
“Attachments” screens, particularly regarding site plans and declaration forms. We found
that Hawaiʻi County collects at least 122 data points (Figure 4.9a) compared to Maricopa
County, Arizona, which collects 27 data points for a Residential New Construction
application (Figure 4.9b).
68 | Audit Results
Figure 4.9a: Comparison of Data Points Collected
Hawai‘i County, HI (122)
Continued …
Figure 4.9a: Comparation of Data Points Collected Hawaii County, HI (122) Compared to Maricopa County, AZ (27).
Figure 4.9a: Comparison of Data Points Collected Hawai‘i County, HI (122) Compared to Maricopa County, AZ (27) Compiled Office of the County Auditor
Hawai‘i County
• Miscellaneous Valuation Information
• Total Number of AC Units
• HVAC/AC Information Details:
• HVAC/AC Details
• Valuation
• Total Number of Pool/Spa(s)
• Pool/Spa Information Details:
• Pool/Spa Details
• Valuation
• Quantity of Heaters
• Total Number of Fireplaces
• Fireplace Information Details:
• Type
• Location
• Valuation
• Total Number of Other Valuation
Items
• Other Valuation Items Details:
• Description
• Valuation
• Plan Review Information
• Type of Construction:
• Various Classifications (e.g., I-FR
Sprinkled, VA, VB, VN Sprinkled,
etc.)
• Occupancy Code:
• R-1, R-2, R-3, R-4, U
• Plans by Qualification
• Foundation Type
• Setbacks:
• Front
• Rear
• Left
• Right
• Distance to Nearest Building (FT)
-End-
122 DATA POINTS
COLLECTED
Hawai‘i County –
New Residential Construction
• Building Info
• Project Declaration Type:
• Contractor
• Declaration Exemption Number
• Work begun without permit
• If work started, are walls open for
inspection?
• Violation Number (if applicable)
• Type of Use with Proposed Work:
• Single-Family Dwelling
• Examples of Accessory Structures:
Retaining Wall/Fence, Detached
Garage, Water Tank/Pool
• Project Type:
• Private
• Special Project Classification:
• County Government Project
• Habitat for Humanity
• Hawaiʻi Community College's Model Home Project
• Major Disaster Recovery
• Number of Building Stories
• Number of Units
• Multiple Building Structure - Building ID
• Square Footage:
• New Floor Area
• Major Floor Area
• Accessory Floor Area
• Utilities
• Desired Method of Permit Delivery
• Total Number of Water Tanks
• Water Tank Info Details
• Water Tank Details
• Valuation
• Sewer Connection Type:
• Public
• Private
• Septic
• Cesspool
• Other
• Meter Equipment Exceeding 200 Amps
• PV Installation Location:
• Roof Mount
• Ground Mount
• PV Info Details:
• PV Details
• Valuation
• Batteries Valuation Details:
• Battery Details
• Valuation
Hawai‘i County
• Batteries Valuation Details:
• Battery Details
• Valuation
• Retaining Wall Information Details:
• Location
• Valuation
• Max Height
• Project Includes
• Pre-Approved House Package
Number
• Principal Type of Frame
• Building Height
• Roofing Type
• Exterior Finish
• Interior Finish
• Number of Bedrooms
• Number of Full Bathrooms (4 or
more require plumbing
plans/diagrams)
• Number of Half Bathrooms
• Number of Garages
• Number of Carports
• Number of Detached
Bedrooms/Guestrooms
• Number of Washers
• Number of Dryers
• Number of Laundry Trays
• Water Heater Info Details:
• Type
• Water Heater Details
• Valuation
• Other Details:
• Skylights
• Basement
• Porches
• Patio Cover
• Decks
• Lanai
• Bar Sinks
• Fire Sprinklers
• BBQ
• Tiki Torches
• Electric Vehicle Charging Station
• Free Standing Sculpture
69 | Audit Results
Figure 4.9b: Comparison of Data Points Collected
Maricopa County, AZ (27)
Figure 4.9b: Comparison of Data Points Collected Hawai‘i County, HI (122) Compared to Maricopa County, AZ (27) Compiled Office of the County Auditor
The EPIC-ENERGOV portal is an opportunity to collect unique essential data. During the
audit period, data was collected redundantly from plans, the portal, and forms.
Maricopa County, AZ –
Building New Construction
• Number of Stories
• Building Height
• Number of Units
• Included in Plan:
• Accessory
• Pools and Spas
• Fence
• Minor Plumbing
• Minor Electrical
• Minor Mechanical
• Solar Water Heater
• Solar Roof Mounted
• Fire Sprinklers
• Pool Type
• Electrical Upgrade
• Miscellaneous Information
• Fence Length (in feet)
• Fence Type
• Propane Tank (Gallons)
• Pool Perimeter Length
• Solar System Size (KW)
• Service Providers
• Electric Provider
• Gas Provider
• Water Provider
• Sewer Provider
• Fire District
-End-
27 DATA POINTS
COLLECTED
70 | Audit Results
Step 5. Attachments
Figure 4.10: Step 5 “Attachments” from EPIC System
The “Attachments” screen is designed to collect required external documents (Figure 4.11).
Building Permit Application Checklist.18
The building permit application checklist includes additional documents required with the
application including:
Figure 4.11: Comparison of Required vs Contingent Documentation
Documents Required
for All Permit Types
Depends on Permit type
Geography of permit*, Age of building**
Licensed Design Professional, Permit
Contact (Architect or Structural Engineer)
with an email address
Proof of Ownership-Depending on if
recently purchased
Property Owner with an email address,
Permit Contact
Residential PV Worksheet
Property Owner Declaration Form Building Division ADA Certification or
Documentation of ADA Exemption
Building Division Special Inspections Form Disability and Communication Access
Board (DCAB) Review/Approval Letter
Project Declaration Form Approved Solar Water Heater Variance
Approval
Acknowledgement Letter from the Kailua
Village Design Commission or the Pahoa
Village District
Habitat for Humanity Approval
Documentation
Flood Zone Packet
*Note Flood Zone maps and form links are
broken
Building Division Ag Structure Declaration
of Compliance for HRS §46-88 (Act 203)*
Department of Hawaiian Home Lands
(DHHL) Approval*
Building Division Historic Property
Certification Form**
Figure 4.11 : Comparisons of Required vs. Contingent Document. Compiled Office of the County Auditor
18 County of Hawai‘i DPW Building Division. “Permit Application Checklist.”
https://records.hawaiicounty.gov/weblink/1/edoc/140083/BLG_Permit_Applicant_Checklist.pdf. Accessed: 1/2/25
71 | Audit Results
We found.
The Project Declaration form is a requirement, but BD’s portal instructions mislead
applicants by indicating it is optional. BD website guidance states:
“If the contact you would like to add does not exist within our system, please
provide their information on either the property owner declaration form or the
project declaration form.”
These contradicting instructions create confusion about whether one or both declaration
forms are required or need to be included. Both are required. This is further complicated by
instructions stating:
“Both forms are form-fillable PDFs and may be completed electronically,
then attached to this case in the attachment area of the application.”
Additionally, BD requires a wet signature, meaning the form must be printed, signed,
scanned, and uploaded. This misleading instruction is one of the most common errors.
• Electronic Plan Review Guide.
The purpose of this guide is to consolidate instructions into a single source for
different users navigating the system. It includes an overview for the general public,
homeowners, real estate agents, and others, along with a review process flowchart.
There are two versions of the same document titled “Electronic Processing &
Information Center Application Guidelines - Electronic Drawing Format,” one
version, dated April 18, 2023,19 is available on the County’s DPW website, while a
more recent version, dated June 3, 2024,20 is accessible only on the EPIC portal.
When multiple versions exist, confusion and errors increase.
In the June 3, 2024 version, the "Revisions and Resubmittals" section requires design
professionals to annotate plans using the “Cloud+Delta” directive outlined in
Memorandum No. 23-003. This memo is not easily accessible in the Building Forms
library, Permit Applicant Checklist, or the EPIC portal. Users must search for it on the
County’s DPW website on the Design Details & Guidelines page. Consolidating
guidelines into a single location would increase transparency while reducing errors.
19 County of Hawai‘i DPW Building Division. Electronic Processing & Information Center Application Guidelines Electronic Drawing
Format April 18, 2023 Version 1.5. https://records.hawaiicounty.gov/weblink/1/edoc/140085/BLG_EPlan_Review_v15_20230418.pdf Accessed: 1/2/25
20 County of Hawai‘i DPW Building Division. Electronic Processing & Information Center Application Guidelines Electronic Drawing
Format June 03, 2024 Version 1.6. https://www.hawaiicounty.gov/home/showdocument?id=306099&t=638531758415813169 Accessed:
1/2/25
72 | Audit Results
• Property Owner Declaration Form.21
This legacy form verifies property ownership, authorizes permit submission, and
ensures all listed contacts receive application-related communications. It requires a
parcel number and location address, which are already collected in the portal’s
'Location' screen, making the form redundant.
This legacy form, a common cause of application rejections, is unnecessary as the
portal supports digital signatures. While HCC §5-4-1(a)(7) requires the owner's
consent via signature, digital signatures are legally equivalent to wet signatures,
making the form obsolete.
• Project Declaration Form.22
This legacy form requires applicants to specify their role in the project, identifying
whether they are licensed contractors or owner-builders. Licensed contractors must
provide licensing details. This form is a common reason for rejection due to missing,
unsigned, or incorrect submissions. This form was initially developed to create
compliance with Chapter 444 Hawai‘i Revised Statutes; however, the portal is
capable of collecting this information, making it obsolete.
Step 6. Signature
Figure 4.12: Step 6 “Signature” from EPIC system
The “Signature” screen is designed to collect the digital signature, where the applicant
certifies and confirms the accuracy of the information and authorization to apply for a permit
on the specified property. By typing their name as an electronic signature, the applicant
attests to their awareness of relevant regulations.
Hawai‘i Revised Statutes §489E-723 grants legal recognition to electronic records,
signatures, and contracts. It ensures that electronic forms cannot be denied legal effect or
enforceability solely due to their format. Additionally, electronic records fulfill writing
requirements, and electronic signatures satisfy signature requirements.
21 County of Hawai‘i DPW Building Division. Property Owner Declaration Form.
https://www.hawaiicounty.gov/home/showdocument?id=306136 Accessed 1/2/25
22 County of Hawai‘i DPW Building Division. Project Declaration Form.
https://www.dpw.hawaiicounty.gov/home/showpublisheddocument/306224 Accessed 1/2/25
23 Hawaii Revised Statutes §489-E7(d) Legal recognition of electronic records, electronic signatures, and electronic contracts.
https://www.capitol.hawaii.gov/hrscurrent/Vol11_Ch0476-0490/HRS0489E/HRS_0489E-0007.htm Accessed 3/28/25
73 | Audit Results
Not utilizing appropriate technology creates unnecessary barriers, even though HRS §489-
E7(d) recognizes electronic signatures as legally valid. HCC §5-4-1(a)(7) does not require a
wet signature. The EPIC system already includes a built-in digital signature function that
could be used to streamline the process.
Figure 4.13 Screen shot of digital signature from EPIC system
Step 7. Review and Submit
Figure 4.14: Step 7 “Review and Submit” from EPIC system
At the “Review and Submit” stage, the applicant is charged the greater of 20 percent of the
original permit fee (Figure 4.14) or a minimum fee of $50, as specified in HCC § 5-7-19(a).
This charge represents an initial fee collection. The final collection may include additional
fees for resubmittals or a plan review adjustment fee due to permit valuation.
Figure 4.14: Fee Schedule
Figure 4.14: Hawai‘i County Code 5-7-3 (b) Fee schedule. Permit Fees.
74 | Audit Results
Accountability and Transparency.
In addition to previous explanations, additional opportunities exist to simplify processes and
improve service delivery. Lean Six Sigma eliminates inefficiencies and reduces complexity.
Certain administrative and procedural challenges continue to hinder the department’s
ability to operate efficiently. Process improvements should enhance efficiency and fairness
in three key areas: application completeness criteria, complaint handling, and staff training.
We found.
• Application Completeness Criteria.
The Tinner Report recommended defining a complete permit application by
ordinance to create clear expectations and reduce inefficiencies. Although Chapter
5, Article 4 Permit Application provides an overview of what is required, the section
has not been updated to reflect electronic document handling since 2020. This lack
of clarity leads to frequent resubmissions, processing delays, and frustration for both
parties. Without a standardized definition, staff rely on discretionary judgment,
increasing inconsistencies.
In addition to defining application completeness, the division would benefit from a
uniform process for addressing complaints. When complaints are handled
inconsistently or bypass formal channels, it can disrupt workflows and create
perceptions of unequal treatment. A standardized approach would promote fairness,
maintain operational focus, and support consistent service delivery for all
applicants.
This lack of clarity leads to frequent resubmissions, processing delays, and
frustration for both parties. Without a standardized definition, staff rely on
discretionary judgment, increasing inconsistencies. A clear legal standard would
improve transparency, streamline processing, and reduce unnecessary back-and-
forth.
• Complaint Handling.
Complaints are addressed through a Request Assistance form or by emailing
cohbuild@hawaiicounty.gov. Management reported that applicants sometimes
seek to expedite project reviews by raising concerns with the administration, which
impacts staff efficiency in managing the queue. In-person and phone inquiries are
also disruptive. Applicants who experience delays in the permitting process
frequently escalate their concerns directly to the administration. These complaints
are prioritized over others, often resulting in quicker resolutions. However, this
prioritization creates a perception of unequal treatment, as applicants without direct
access to administrative channels may experience delays.
75 | Audit Results
No policies, procedures, or administrative rules outline uniform complaint handling
to prevent administrative pressure from prioritizing certain applications over others
in the queue. Complaints vary widely in how they are addressed based on who
receives them and the level of attention they receive. Staff are frequently pulled from
routine tasks to fast-track priority complaints, affecting the department's standard
workflow. Applicants who do not similarly escalate their concerns are
disadvantaged.
• Staff Training.
The Tinner Report recommended that staff receive expert training from an external
consultant specializing in lean process improvement. Specialized training would
reduce non-value-added steps, make data-driven decisions, and improve
application consistency. However, despite the recommendation, staff did not receive
the recommended training, and the process remained undocumented, with no
targeted date for a structured review to identify and eliminate unnecessary tasks.
Subsequently, during the audit, management also suggested consulting with a
specialist familiar with the EPL’s features to provide guidance and recommendations
for improving workflows and processes.
Conclusions.
Unnecessary complexity, inconsistencies, and unclear guidance slow the submittal
process, while external forms and cumbersome data entry add redundant steps. Instead of
adapting to align with applicant needs and software capabilities, the system has been forced
to conform to outdated processes, diminishing the intended benefits of modernization.
Challenges remain while the County has tried clarifying requirements and upgrading its
system.
76 | Audit Results
To Reduce Complexity of the Applications
We make the following recommendations
To Simplify “Location” Step:
FINDING 3: Redundant Data Collection
Cause of the Condition
The EPIC portal captures location data during the application process, but this data is not
utilized to prefill other forms or satisfy later steps.
Effect of the Condition
Applicants are required to repeatedly enter the same data, increasing the time and effort
needed to complete the application contributing to errors and frustration.
Recommedation 15
Reduce Redundant Data Collection.
Use information captured early in the process to auto-populate fields in later steps,
eliminating repetitive inputs.
To Simplify “Type” Step:
FINDING 4: Manual Processes Drives the Workflow.
Cause of the Condition
Building Division staff preferences for reformatting project descriptions results in manual
rewriting of applicant-provided information.
Effect of the Condition
Manual rewriting of project descriptions is unnecessary and leads to delays in application
processing.
Recommedation 16
Eliminate Manual Processes.
Eliminate unnecessary project description rewrites. Elements to consider include:
• Update employee guides
• Update applicant instructions in the EPIC portal.
77 | Audit Results
To Simplify “Contacts” Step.
FINDING 5: No Contact Validation and Categorization
Cause of the Condition
The system does not sort or validate contact information, mixing trade professionals with
other users and failing to ensure licensing compliance.
Effect of the Condition
Errors in contact categorization contribute to application rejections and delays.
Recommedation 17
Validate and Categorize Contact Information.
Implement data validation to ensure contacts are accurately categorized (e.g., licensed
professionals versus property owners). Create separate lists or filters for trade
professionals in good standing.
To Simplify “More Info” Step.
FINDING 6: Insufficient Clarity to Guide Data Collection
Cause of the Condition
Many data fields lack tooltips or explanations, making it unclear what is required. The
system redundantly collects information already captured in prior steps or attached
documents. Automation opportunities, including auto-populating pre-approved plan
data, remain underutilized.
Effect of the Condition
Redundant data entry causes delays.
Recommendation 18
Refine the "More Info" Screen.
Streamline data collection by eliminating redundancies between the "Type" and "More
Info" screens. Focus on essential inputs and pre-populate or exempt input fields for
known values, such as pre-approved house package numbers.
78 | Audit Results
To Simplify “Attachments” Step.
FINDING 7: Building Division Uses Outdated Forms
Cause of the Condition
Despite software modernization, inconsistent instructions and outdated forms from prior
practices are still used.
Effect of the Condition
Misleading instructions and the requirement for wet signatures create unnecessary
burdens on applicants, contributing to high rejection rates.
Recommedation 19
Eliminate Outdated Forms.
Remove the Property Owner and Project Declaration Forms by integrating their essential
data directly into the portal. This reduces the need for applicants to provide the same
information in multiple places.
To Simplify “Signature and Review” Step.
FINDING 8: Not Utilizing Digital Signature Feature
Cause of the Condition
The digital signature feature is limited in application and does not replace wet signatures
required for declaration forms.
Effect of the Condition
Not replacing wet signatures with digital signatures prolongs processing times.
Recommedation 20
Enable Digital Signature.
Allow digital signatures across all forms, replacing physical wet signatures to simplify
and accelerate the application process.
79 | Audit Results
To Improve Accountability and Transparency.
FINDING 9: Improve Accountability and Transparency
Cause of the Condition
1. Application Completeness Criteria: There is no ordinance or guidance in the
rules defining what constitutes a complete application.
2. Complaint Handling: There is no standardized policy or procedure for handling
applicant complaints uniformly.
3. Staff Training. The division has not implemented structured training programs in
Lean Six-Sigma principles or process improvement methodologies.
Effect of the Condition
1. Application Completeness Criteria: The absence of an ordinance clearly
defining a complete application leads to frequent resubmissions, delays, and
inconsistent expectations between staff and applicants.
2. Complaint Handling: Without a formalized complaint-handling process,
applicants who escalate their concerns directly to the administration receive
preferential treatment, while others experience longer delays, creating a
perception of inequity in service delivery.
3. Staff Training: The absence of Lean Six Sigma training leads staff to add
redundant steps and workarounds instead of eliminating inefficiencies. Over
time, this compounds process complexity, increasing delays and making future
improvements harder to implement because BD is learning basic configuration
and capabilities.
Recommedation 21
Define Application Completeness by Ordinance.
Establish a legally binding definition of a "complete" permit application through
ordinance, or administrative rules.
Recommendation 22
Implement a Formal Complaint Handling Process.
Develop and implement a standardized complaint-handling system, preferably electronic,
that ensures uniform treatment of applicant concerns. Establish policies and procedures
that define complaint prioritization criteria, response timelines, and escalation protocols.
80 | Audit Results
Recommendation 23
Integrate Lean Six-Sigma Training into Staff Development.
a. Engage a Lean Six-Sigma Expert Consultant – Conduct a comprehensive
evaluation of permitting workflows to identify and eliminate non-value-added
steps.
b. Train Staff in Lean Six-Sigma Principles – Establish a structured training
program through policies and procedures that embed process improvement
methodologies and require continuous re-evaluation and adaptation to
operational changes.
County of Hawaiʻi Of�ice of the County Auditor
Chapter 2: Audit Results
Inspections
81 | A udit Results
Audit Activity.
To identify gaps in the inspection process, we:
• Gained an understanding of the inspection process through:
o Site visits
o Ride-alongs with eight inspectors and one inspector aide
o Interviews with four supervisors and three staff members
o Observations of monthly Building, Electrical, and Plumbing meetings
o Review of Building Division Inspection Reports
o Review of complaint reports and meeting notes
• Reviewed relevant governance:
o Hawaiʻi County Code (HCC) § 5-8-1, Article 8 Inspections
o 2018 State Building Code
o Government Accountability Office (GAO) The Green Book24
o Tinner Report
We participated in ride-alongs to observe the inspection process, comparing county codes,
job descriptions, and supervision. Eight ride-alongs were scheduled: six in Hilo with
Building, Electrical, and Plumbing Inspectors and two in Kona with Building Inspectors.
Electrical inspectors must hold supervising electrical journeyman licenses. Plumbing
Inspectors must hold a plumbing journeyman license. Despite their role in final
walkthroughs and permit sign-offs, the Kona Building Inspectors are not required to be
licensed.
One of the Building Inspection Supervisors was evasive to auditors' multiple requests for
ride-alongs. After repeated attempts, it was decided to discontinue pursuing their
participation to avoid further delays.
Site visits included interviews with inspection supervisors in Hilo and Kona and attendance
at monthly Building, Electrical, and Plumbing meetings. Interviews with building inspection
supervisors and select inspectors highlighted management concerns about the inspection
process.
24 U.S. Government Accountability Office (GAO). Standards for Internal Control in the Federal Government (The Green Book). September
2014, by the Comptroller General of the United States. https://www.gao.gov/assets/gao-14-704g.pdf (accessed February 12, 2025)
82 | Audit Results
Inspections Overview.
When construction begins, inspections are conducted at various stages to ensure that work
complies with applicable codes, adheres to local regulations, and aligns with the approved
plans. Hawaiʻi County Code § 5-8-3 outlines the process for requesting these inspections.
According to HCC § 5-8-3, the contractor or appropriate trade professional must file a
request for inspection with the authority having jurisdiction, and requests may be submitted
in writing, in person, online, by facsimile, or by telephone if allowed. It is the responsibility
of the person doing the work to ensure that the construction will pass all prescribed code
requirements under the construction code before requesting an inspection.
Requests for inspection must be submitted no less than two working days and no more than
three working days before the desired inspection date. Once a request is received, the
jurisdiction authority will inspect within two working days (excluding weekends or holidays)
or arrange with the contractor to reschedule for a later date if necessary.
Inspectors use the mobile version of EPIC on tablets during inspections. This tool
centralizes project elements and loads inspection data. However, it cannot load plans
when there is no wireless access. Plans can be downloaded to the application before
conducting the inspection. Additionally, an approved permit requires that plans be kept on
the job site at all times per Section 5-5-6 of the Construction Administrative Code. The
permit holder is responsible for keeping the work accessible and exposed for examination.
Additionally, supervising professionals, such as the contractor, electrician, or plumber, may
be required to be present on-site. The inspector’s role is to assess compliance with the
construction code and either approve the work or issue a written notice detailing any
deficiencies. If non-compliance is identified, the work must be altered, corrected, or
removed to meet code requirements before proceeding.
For new residential construction, required inspections typically include:
• Foundation/Slab – The foundation/slab inspection is the first step in the permit
inspection process. Once construction work is finished in this phase, the
owner/contractors for the specific disciplines must request inspections for
electrical, plumbing, and building work performed. After the electrical and plumbing
inspections are approved, a building inspection is conducted, and upon passing,
construction is allowed to proceed with a concrete pour and framing.
83 | Audit Results
• Framing - After construction work is finished, owners/contractors for the specific
disciplines request inspections for electrical, plumbing, and building work
performed. Once approved and the inspection passes, construction can proceed to
the final phase.
o Insulation
o Lathing (support, underlayment backing)
o Electrical
o Plumbing
• Final - After construction, a final inspection, including plumbing, electrical, and
building inspections, is requested. Once approved, the project receives sign-off and
is ready for occupancy.
Certificate of Occupancy (CO).
• COs only apply to nonresidential construction. These structures cannot be used or
occupied, nor can the occupancy classification be changed until the appropriate
authority has issued a certificate of occupancy.
• Exception for the Certificate of Occupancy is :
o Group R-3 (Residential, Division 3) typically includes single-family homes,
duplexes, and townhouses not more than three stories high.
o Group U (Utility and Miscellaneous) includes private garages, carports,
sheds, agricultural buildings, and other accessory structures.
While the building permit process coordinates and ensures compliance with permits issued
by other agencies, it does not manage inspections for those agencies. Therefore, agencies
such as the Engineering Division, Fire Department, Planning Department, Department of
Environmental Management Wastewater Division, Department of Health Food Safety
Division, and Department of Health Wastewater Division must approve the construction
before issuing a Certificate of Occupancy.
84 | Audit Results
We Found.
Policies and Procedures.
The Building Division lacks written policies and procedures for management oversight and
permit inspections, leading to inconsistencies across all inspection disciplines. Inspectors
operate autonomously and develop their inspection methods, resulting in variations in
documentation, inspection standards, and enforcement practices. This inconsistency
creates challenges when inspectors swap work areas and when permits must be reassigned
due to absences.
Additionally, there is no standardized requirement for documenting inspections, such as
photographing placards, plans, or critical failures or entering inspection reports onsite. As a
result, documentation practices vary, and reports are often completed after the fact,
increasing the overall timeline.
The GAO’s Green Book requires management to document policies to ensure effective
oversight, risk mitigation, and operational consistency. Specifically:
• 12.03: Management must document responsibilities and control activities necessary
for operational effectiveness.
• 12.04: Policies should define procedures, including the timing and corrective actions
needed when deficiencies are identified.
• 12.05: Policies and procedures must be periodically reviewed to ensure continued
relevance and effectiveness.
Conclusion.
Without written policies and procedures aligned with these standards, the BD lacks a
structured framework for inspections, increasing the risk of inconsistent enforcement,
miscommunication, and oversight.
85 | Audit Results
To Improve Inspections Practices
We make the following recommendations
FINDING 10: No Policies and Procedures
Cause of the Condition
The lack of documented policies and procedures for management oversight and permit
inspections is caused by the absence of a consistent framework and clear guidelines.
Effect of the Condition
Without documented policies and procedures, management oversight and permit
inspections lead to potential inefficiencies and difficulty maintaining uniform standards
across disciplines.
Recommedation 24
Establish Policies and Procedures.
We recommend the Building Inspections Group create written policies and procedures for
management oversight and inspections to ensure consistent field practices across
disciplines.
86 | Audit Results
Management Oversight.
The Building Division lacks consistent management oversight across inspection teams,
resulting in variations in supervision, work review, and enforcement of inspection standards.
While supervising inspectors are responsible for verifying subordinate’s work, resolving
complaints, and ensuring team safety, there is no standardized approach to how these
responsibilities are carried out. Inconsistency creates gaps in accountability and quality
control across disciplines.
Additionally, inspection supervisors are required to review plans for permitting. Therefore,
supervisors were not assigned vehicles; instead, they did “ride-alongs” with staff to verify the
accuracy of inspections. Without direct field oversight, management cannot ensure that
inspections are performed consistently or that deficiencies are addressed promptly.
The GAO’s Green Book emphasizes management’s responsibility for oversight, control, and
remediation of deficiencies, specifically:
• Principle 2 - Oversight of the Internal Control System: Management must establish
oversight mechanisms to monitor operations, assess risks, and ensure control
activities are effectively implemented.
• Principle 2 - Input for Remediation of Deficiencies: Management is responsible for
identifying and addressing control weaknesses to improve operational effectiveness.
Conclusion.
Without a structured oversight framework, the BD lacks controls to ensure uniform
inspection practices, timely issue resolution, and accountability in the field.
FINDING 11: Limited Management Oversight
Cause of the Condition
Management allowed inspection supervisors autonomy, resulting in variations in oversight
processes and limited access to resources, such as vehicles, leading to inconsistencies
in inspection practices, including limited field spot-checks and lack of standardized
procedures for work review, issue resolution, and safety enforcement.
Effect of the Condition
Customers experience inconsistent service quality, and inspectors face inconsistent
guidance.
Recommedation 25
Increase Management Oversight.
We recommend that BD Inspection teams strengthen management oversight by
developing standardized procedures for reviewing work, resolving issues, and routine
spot-checks. Supervisors should have daily access to vehicles to support effective
oversight.
87 | Audit Results
Training.
The Building Division lacks a formalized and comprehensive training program for inspection
supervisors and inspectors, resulting in inconsistent proficiency levels with critical tools and
evolving industry standards. Inspectors require additional training on the EPIC application,
tablets, and inspection tools to utilize available resources fully. Supervisors who must
analyze backend inspection data have varying proficiency levels with EPIC, limiting their
ability to oversee and evaluate inspections effectively.
Additionally, when industry codes change, there is no structured process to ensure all
inspectors receive necessary updates, creating a risk of outdated practices. Specific
inspection teams, such as Electrical Inspectors, have requested specialized training in key
areas like medical facilities and large PV farms, which would benefit other disciplines.
The GAO’s Green Book emphasizes the need for management to recruit, develop, and retain
competent personnel, stating:
• 4.05: (Training) Management must enable personnel to develop role-specific
competencies, reinforce standards, and tailor training to meet operational needs.
Conclusion.
Without a structured training program aligned with these principles, the division risks errors
and non-compliance with industry standards, ultimately affecting the quality and
consistency of inspections.
FINDING 12: Lack of Training.
Cause of the Condition
No ongoing training for supervisors and inspectors on the EPIC application, tablets, and
specialized inspection areas.
Effect of the Condition
Staff are underutilizing the technology.
Recommedation 26
Develop Training Program.
Establish a formal, ongoing training program for the inspections group after EPL is
configured that includes:
• Training on the EPIC application and tablets, in collaboration with the EPIC
application project team
• Develop targeted training modules for specialized inspection areas
• Implement procedures to provide regular refresher training when applicable
industry code changes are adopted
• Develop a process to track employee participation (e.g., sign-in sheets, staff
records) and maintain a record of completed training sessions
88 | Audit Results
EPIC Enhancements.
Certain critical controls for effective management oversight, data security, and operational
efficiency have not been operationalized. Currently, all supervisors, inspectors, and
inspector aides share the same access privileges, increasing the risk of unauthorized
changes and compromising data security. Additionally, the software allows personnel to
backdate inspection reports without time limitations. Auditors observed reports entered
weeks to months after the original inspection, raising concerns about the accuracy and
reliability of the documented findings. Without role-based access controls, sensitive
information remains vulnerable, and the principle of segregation of duties is not upheld.
Additionally, EPIC does not generate exception reports. Exception reports are summaries
that flag errors or anomalies. Without exception reporting, it is difficult for supervisors to
identify inspection inconsistencies, errors, or trends requiring corrective action. Without this
functionality, oversight is weakened, reducing accountability and limiting management’s
ability to address performance issues.
Another significant issue is the inaccuracy of geo pin locations, which results in difficulty
locating inspection sites. This problem was observed in nearly every ride-along, causing
inefficiencies, wasted time, and potential errors in inspection records.
The GAO’s Green Book emphasizes the importance of application controls and security
management in internal control systems:
• 11.08: Design of Appropriate Control Activities: Application controls should ensure
data validity, completeness, accuracy, and confidentiality.
• 11.14: Design of Security Management: User access should be restricted based on
job responsibilities, ensuring proper segregation of duties and timely updates when
roles change.
Conclusion.
Because BD did not apply critical enhancements, EPIC remains insufficient for ensuring
secure access, consistent oversight, and operational accuracy, undermining the efficiency
and reliability of the inspection process.
89 | Audit Results
FINDING 13: Lack of Critical Enhancements.
Cause of the Condition
The EPIC system was only configured for inspection and supervisor and inspector) user
roles limiting role-specific functionality. Additionally, the absence of an exception report
for inspections hinders effective monitoring and oversight. Furthermore, the Geo Pin
software has limitations in accurately determining the location of some project sites on
the island.
Effect of the Condition
The lack of role differentiation in the EPIC system limits functionality, reducing efficiency
and oversight. The absence of an exception report hinders the monitoring of inspections,
increasing the risk of non-compliance. Additionally, Geo Pin software inaccuracies can
misidentify project site locations, leading to wasted time, potential errors, and delays in
inspections.
Recommedation 27
Opportunities for Critical Enhancements.
We recommend that the Building Division implement the following:
• Implement role-based access controls in EPIC, assigning separate privileges based
on job functions such as Supervising Inspectors, Inspectors, and Inspector Aides.
• Develop exception reporting to monitor and address potential inspection
abnormalities.
• Enhance Geo pin functionality to improve job site location accuracy.
90 | Fraud, Waste, and Abuse
Chapter 3
Fraud, Waste, and Abuse
As a practice, we remain mindful and document instances of fraud, waste, and abuse within
the scope of the audit objective and not departmentwide or countywide.
During the audit, management reported ongoing investigations and pending litigation.
What is the Definition of Abuse?
“Abuse” involves deficient or improper behavior compared to behavior that a prudent
person would consider reasonable and necessary given the facts and circumstances. This
includes the misuse of authority or position for personal gain or the benefit of another.
Abuse does not necessarily involve fraud or illegal acts.
Inspectors play a critical role in the building process by ensuring compliance with codes,
regulations, and safety standards. Their approval is required at key stages of construction,
influencing project timelines, costs, and overall feasibility. Their decisions can expedite or
delay progress, and any inconsistencies, errors, or misconduct in inspections can impact
structural integrity, safety, and regulatory compliance.
We identified disciplinary actions against employees within the inspection group during the
audit. The Office of the County Auditor also received multiple complaints through its Fraud,
Waste, and Abuse Hotline. While a complaint alone does not confirm wrongdoing, the
allegations raised included the following:
• A contractor claimed an inspector approved inspections by phone without going
onsite.
o The allegation was reported under the condition of anonymity, the
inspector was not named, and OCA was not able to substantiate
the allegation.
• An inspector takes money in exchange for favorable inspection outcomes.
o The allegation was reported anonymously, and the OCA was not
able to substantiate it.
91 | Conclusion
• Inspectors approve inspections without going onsite and backdating entries into the
system.
o This allegation was reported by DPW leadership, who
subsequently initiated disciplinary action against the
employee(s). We commend their transparency in reporting the
issue and taking corrective action.
These actions may be considered abusive behavior when the allegations are confirmed to
be accurate. Determining whether a specific act constitutes abuse often requires a legal or
adjudicative process beyond the auditor's role.
Recommendations made throughout this report, particularly with regards to the Inspections
Group, if enacted in good faith, will:
Policies and Procedures.
• Require inspectors to take pictures of placards, sites, and critical failures to ensure
they are onsite for each inspection and dispel claims to the contrary.
EPIC Enhancement.
• Role-Based Access Controls: Setting up access by user role ensures that entries
cannot be backdated without prior approval from the building chief or their designee.
This protects inspectors from potential accusations of improper recordkeeping and
ensures accountability is shared at an appropriate level.
• Exception Reporting: Automated exception reports provide monitoring to detect,
prevent, and deter anomalous entries. This promotes good recordkeeping habits,
reinforces accountability, and helps ensure that employees' work is consistently
documented.
Public trust in the inspection process is vital, and all stakeholders—government officials,
contractors, and the community—play a role in upholding fairness and compliance. We
encourage vigilance and accountability to ensure the system serves its intended purpose
without undue influence or misconduct.
We encourage employees and members of the public to report instances of waste, fraud,
and abuse in county operations.
(808) 480-8213 fraud and waste
(808) 480-8279 abuse
concern@hawaiicounty.gov
92 | Conclusion
Conclusion
W
The Department of Public Works Building
Division audit highlighted persistent challenges
in the permitting and inspection processes,
affecting efficiency, transparency, and public
trust. While ongoing efforts have been made to
streamline operations, systemic inefficiencies
continue to impact applicants, staff, and the
broader community.
Key findings indicate that high application
volumes, inconsistent processing timelines, and
unnecessary complexity contribute to delays.
Although the Building Division has some guides,
workflows, and monitoring practices, some are
outdated, and certain areas lack them. These
gaps highlight the need for process improvements, including providing clear expectations
through administrative rules, policies and procedures, standardized workflows, and robust
monitoring practices. Additionally, the lack of effective oversight in the inspection process
raises concerns about compliance and accountability.
To address these issues, we recommend a multi-faceted approach that tackles the problem
from different perspectives—reducing application volume, improving processing time, and
simplifying complexity. Addressing all three factors simultaneously creates a cumulative
effect that strengthens efficiency and accountability at every level of the permitting process.
Reducing volume through exemptions and self-certification frees up resources for more
complex projects. Improving processing time by enforcing date-driven prioritization and
automation minimizes delays. Simplifying complexity through better public guidance,
clearer requirements, and technology enhancements ensures that applications are
processed correctly the first time.
While management has acknowledged some challenges and taken steps to address
inefficiencies, further commitment is needed to resolve the underlying issues fully. A
comprehensive strategy that integrates these solutions alleviates backlogs and builds a
predictable, transparent permitting system that responds to the community's needs.
Moving forward, ongoing oversight and proactive management will be essential to sustaining
these improvements, ensuring compliance with best practices, and fostering a culture of
accountability and service excellence.
Figure 5: Rubik Cube created, courtesy County Auditor
93 | Management Response
Chapter 4
Management Response
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132 | Attachments
Attachments
Report Regarding Operations within the Building Code Division of the Hawaiʻi County Public
Works Department. An excerpt from Communication 36.1 (2022-24)25:
25 Lee Loy, Susan L.K. Supporting material for Communication 36. Communication 36.1 (2022-24).
https://records.hawaiicounty.gov/Weblink/0/doc/1049842/Page1.aspx Accessed: 4/7/2025.
133 | Attachments
Future Attention
TINNER RECOMMENDATION COMMENT
Implement a technology fee to pay for enhancements to Energov County does not presently charge a fee
Investigate increasing plan review fees to
industry standard (65% of permit fee)
County presently charges 20% permit fee
upfront
Conduct Lean Process Improvement training
https://www.lean.org/ The lean process is a method for creating a
more effective business by eliminating wasteful practices and improving efficiency.
Reviewing County permitting process in a
structured manner could drive out inefficiency
and eliminate non-value-added steps
Provide Public Duty Doctrine training for staff Noted
Investigate allowing building plans reviewers
performing structural review for simple
projects
Will consider after assessing Plans Examiner workload once all vacancies are filled (only
4/7 positions are presently filled); currently,
Structural Engineer's reviews reduces the
workload on Plans Examiners who are primarily focused on life-safety compliance
Investigate allowing building inspectors to
perform combination inspections
Requires consultation with HGEA regarding
work jurisdiction; Inspector positions currently
require Supervisory Electrician Licenses for
Electrical Inspectors and Journeyman or
Master Plumber Licenses for Plumbing
Inspectors
Define by Ordinance what constitutes a
complete permit application
Will evaluate need for an Ordinance after the
effectiveness of the REVISED Application
Checklist is implemented.
Provide support to allow Building Chief and
Deputy to participate in the ICC Committee
Action Hearings and Annual Business Meetings
Noted
Provide additional GIS integration within
EPIC to automatically let applicant know if
subject property has restrictions such as flood
plain or geological hazards
Noted as a future enhancement that can be
used to determine when Engineering Review
will be required for Building Permits
The Building Division is working on a number of approaches to improve permitting.
These are summarized below.
ACTION DESCRIPTION
Communication Improve public outreach with
stakeholders; hold "talk story" sessions
with design professionals, drafters, contractors, others; share review
checklists; improve permit issue metric
and include average duration for
permits to be issued
County of Hawai’i is an Equal Opportunity Provider and Employer.
134 | Attachments
Re-design EPIC Website Organize and make website user-friendly,
including a complete list of forms that are
needed in the permitting process; include
links to related agencies.
Dedicated IT Support for Energov (staff) Improve staff efficiency by having a dedicated
IT specialist available to help troubleshoot
customized automation unique to the Building
Division
ICC Training and Certification for Inspectors
and Plan Examiners
Create classification of work for ICC
Certification that recognizes training and level
of skill of Inspectors and Plans Examiners
Staff Vacancies Develop strategy for hiring and retaining staff;
5-step Plans Examiners for on-the-job
training (done); Certification Classification for
Inspectors (ongoing).
Reassess Duties for Permit Clerks Assessed Permit Clerk duties; revising
processes for permit application, resubmittal and revisions to ensure that documents are
complete and correctly formatted to enable
Permit Clerk to maximize their productivity
Staff Meetings Weekly "Brainstorming" Meetings to identify
areas for improvement; action items identified
in table and progress tracked.
e-Filing Organize documentation in shared drive
readily accessible to the Building Division;
this creates consistency through available
information resources and uniform
procedures
Utilize filters to identify permits that should be prioritized
Deployed Priority Tiles to identify projects
that can be expedited based on the scope of
work that is essential to community life and safety; provides for educational needs; and is
limited and simple for quick review; Priority
Tiles used at permit intake, plan review, and
permit out-processing
Revise Permit Application Checklist Provide more clarity on permit application
requirements with weblinks to the appropriate
agencies and forms; require the Design
Professional to be listed as a Permit Contact;
require Design Professional to review and
certify the Application Checklist
Develop EPIC "Decision Engine" version of the Application Checklist User-friendly version of the checklist
Create "Self-Certify" Permit Application Applicants will have the option bypass the
conventional Permit Intake to reduce
processing time; if Permit Clerks confirm the
permit is complete, then plans will go
immediately to Plan Review; if applications are found to be incomplete, then they will be
County of Hawai’i is an Equal Opportunity Provider and Employer.
135 | Attachments
rejected (cancelled); there is no fee
assessment if the application is rejected; the
conventional review by Permit Clerks will still
be available where the permit application is
"active" while awaiting corrections; once
corrections are submitted then applications
will await re-review in the queue before
progressing
Reject Incomplete Permit Applications Prohibit applications submitted as "place
holders" that then requires Permit Clerks to
contact them for missing information
Update Residential Plans Designer Checklist
Already Posted on the Website
Update for 2018 International Residential Code (IRC) that applicants can use to create a
complete set of plans
Finalize and Post Non- Residential/Commercial Designer Checklist on
the Website
Finalize checklist for current Codes that applicants can use to create a complete set of plans
Plan Resubmittals and Revisions Format Require Corrections Letter for Plan
Resubmittals; require Design Professional
Narrative for Plan Revisions; require all
changes be annotated with the "Cloud and
Delta" drafting method to highlight the extent of changes; utilize Bluebeam "compare"
feature.
Three-strike Rule Plan reviewer can mark up to three
corrections and then approve, "as noted"; if more than three corrections needed,
resubmittal will be required
Encourage Communication between Design
Professional and Plans Reviewer during
Review
Authorize Plans Examiners to have
discussions with Design Professionals when
design intent is not clear; annotate plans to
document revision: "...per telecon with XX on
date" instead of requiring resubmittals.
Consider No Plan Review - "Plans Subject to
Field Inspection"
For Residential PV less than 10kW; Electric ONLY less than 200A; Plumbing ONLY less than 4-bathrooms.
County of Hawai’i is an Equal Opportunity Provider and Employer.
136 | Attachments
Director Lee Lord
Office of the Mayor
Hawai’i County, HI
Report regarding operations within the Building Code Division of the Hawai’i County Public Works Department Project scope: To identify inefficiencies within the building division of the Public Works Department that
may lead to delayed intake, processing, and issuance of building and/ or associated construction
permits.
Project limitation: operations within the fire code division, public works permitting division, planning
department and health department are outside of the scope of this report.
Methodology: Online research of permitting and legal information relative to building and associated
permits as well as face to face interviews with building division permitting staff and a limited number of
permit applicants. Interviews with staff were held between October 3, 2022-October 7, 2022. Staff
interviews were representatives of permit clerks (permit technicians), inspectors, plans examiners and
division managers. Below are general interview questions and generalized responses of each group that
was interviewed.
Permit Clerks:
Q. How do you receive most of you permit applications?
A. Most are received electronically through the EPIC permit system.
Q. I understand that you use Tyler Energov as your permit records system. What does EPIC do that
Energov does not do?
A. The permit clerks could not provide a clear answer to the question however it became clear to me
that EPIC provide enhanced initial permit application ability for the applicants.
Q. Does EPIC require specific information such as building occupancy, construction type, height, etc. to
be input by permit applicant before the application process can continue?
A. No
Q. Does EPIC provide automated geographic information such as whether a property is in a flood hazard
zone to the permit applicant?
A. No
Q. It appears the owner declaration form and contractor declaration forms must be submitted as
separate documents and are not part of the EPIC or Energov systems. Is that correct?
A. Yes, they are separate documents that must be provided by the permit applicant.
Q. Do you issue very many rooftop solar voltaic building permits and if so, can you tell me how many?
A. Yes, we issue a lot of them, but I can’t tell you how many.
Do you require building permits for all rooftop solar installations?
A. Yes
Q. Are simple projects prioritized?
A. To some degree yes but there is no formal procedure for doing so.
Q. May I obtain a copy of your policy and procedure manuals?
A. We don’t have policy or procedure manuals.
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Q. I understand that Hawai’i state law requires that the county verifies the licenses of each contractor
with each permit application. I also understand that the State will provide a list of licensed contractors
for use in required contractor verification. Does the County utilize that list or do you perform an online
search for contractor information with each permit application.
A. The information is within EPIC but it is not automatically validated. Permit Clerks validate the
information prior to permit issuance.
Q. When staff meetings take place is a written meeting agenda distributed to staff?
A. No
Q. Your online checklist shows that once all reviews are approved, the applicant must come to the
building division do have a permit placard printed to be posted on the jobsite. What is the purpose of
the placard?
A. So that the inspector driving by knows there is a permit for the work being done.
Plans examiners:
Q. Do you use Bluebeam Revu to conduct your reviews?
A. Yes
Q. Is Revu integrated with Energov?
A. I don’t think so.
Q. How do you know when a new project is ready for review?
A. (A little ambiguous). We are notified by the permit clerks.
Q. Do you prioritize simple projects to get them “out the door” more quickly?
A. Somewhat, yes.
Q. When minor corrections are needed on the plans do you redline them and approve the plans?
A. Sometimes.
Q. When corrective items are noted on plans do you attempt to contact the designer by phone and/ or
email or do you always input the corrections into Energov without additional contact attempt methods?
A. Corrections are entered into Energov. We typically do not use additional contact methods.
Q. When are plans sent to the structural engineer for review?
A. When the other plans examiners determine structural review is needed.
Q. Are you familiar with the Public Duty Doctrine?
A. No.
Q. When workloads are overwhelming, do you utilize third party plan review?
A. We’ve done so on a vey short term basis in the past.
Q. Do you require the industry standard delta and revision cloud when changes are made on plans?
A. No
Q. Do you use the “compare” feature in Bluebeam Revu to identify what changes are made to different
iterations of plans?
A. No
Q. Does your division use the ”Sessions” feature of Bluebeam Revu?
A. Yes
Q. Do you have an ordinance or policy that defines what a “complete” set of plans is?
A. No
Q. Do you require an engineer or architect to analyze the impact of rooftop solar systems on the
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building’s roof structure?
A. Yes
Inspectors:
Q. Do you require licensed plumbers to perform plumbing inspections?
A. We have dedicated inspectors that perform plumbing inspections.
Q. Does state law require that plumbing inspectors be licensed plumbers?
A. Unsure
Q. Must final plumbing inspections be completed prior to calling for the building final inspection?
A. Yes
Q. Can the general contractor request plumbing inspections?
A. No. Only the plumbing contractor can request plumbing inspections.
Q. When electrical inspections are requested is the general contractor allowed to request the
inspection?
A. No. Only the electrical contractor is allowed to request electrical inspections.
Q. Is there a state requirement that electrical inspectors be licensed electricians?
A. We believe that the answer is “yes”
Q. Do you allow building inspectors to perform inspections for minor plumbing and/ or electrical
installations?
A. No
Q. When a rooftop solar installation is inspected, does the building inspector go on the roof to check the
structural connections?
A. No
Q. When the rooftop solar installation electrical inspection is called for, does the electrical inspector
look at the structural connections on the roof?
A. No
Q. Do you allow any level of self-certification for minor maintenance permits such as water heater
change-outs?
A. No
Conclusions:
Permit processing systems are extremely complex. Without written documentation such as
policy/procedure manuals it becomes extremely difficult to keep complex systems organized and
predictable for permit staff and permit applicants. The result is inefficiencies, personal preferences, and
some level of chaos creeping into the system. These items lead to non-predictability for permit
applicants which in turn leads to unnecessary complaints to upper management and elected officials.
The lack of written meeting agendas leads to ineffective use of staff time during staff meetings. If there
is no agenda, there should be no meeting.
As you know, there are a significant number of open plan review positions. This is not unique to Hawaii
County but rather is an industry-wide concern. It’s somewhat worsened by the low rate of pay being
offered by Hawaii County. Third-party plan review is a possible solution and seems to be the trend in the
industry.
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The current plan review fees being charged might make it difficult to retain the services of third-party
review. Current building plan review fee is 20% of the building permit fee. Industry standard and the fee
called out in in the generic International Building Code (IBC) is 65% of the building permit fee. As you are
aware, raising fees brings political implications.
Compartmentalization of duties among inspection staff also leads to inefficiencies as does assignment of
virtually all structural plan review being performed by licensed engineering staff in the plan review
section. Using licensed engineers to perform structural review projects scoped up to conventionally built
single-family houses is extremely unusual in the industry. Finding a third-party plan review firm that
would utilize this practice would hover somewhere where the needle is close to “Impossible”. There also
appears to be an extreme over reliance on internal engineering staff even though the project has been
designed by licensed design professions such as architects or engineers. The talents and expertise of
internal licensed staff is best reserved for extremely complex structures. This over reliance appears to
(at least in part) stem from extreme risk intolerance. Such intolerance can be partially muted with
training in the tenants of the Public Duty Doctrine.
Rooftop photovoltaic systems are typically extremely light weight (typically less than 4 PSF) Research
and experience in major southwest mainland jurisdictions has demonstrated that there is little benefit in
requiring the time and expense of requiring licensed design professionals to design these systems.
Washington State as example, specifically exempts systems meeting established criteria from requiring a
licensed design professional. It’s estimated that well over 95% of rooftop systems fall within the
limitations established by Washington State. Several jurisdictions have decided that building permits for
these systems provide no benefit other than collection of permit fees so no longer require building
permits but rather simply issue an electrical permit and ask the electrical inspector to verify required fire
fighter access paths from the ground when they perform the electric inspection.
There are several other areas where staff can be better utilized such as allowing the building inspector
to perform plumbing inspections at the same time as the framing inspection for simple structures such
as single-family homes.
While there may be some benefit in not allowing the general contractor to call for plumbing or electrical
inspections, the benefit is extremely minor but is quite an inconvenience to the permit holder. It is also a
procedure I’ve not seen in my 34-year career.
There are some additional efficiencies that can be made but would require minor changes to the County
Code.
Staff members I interviewed were all unaware of what a Lean Process Improvement program is. Lean
process improvement program involves a Lean Consultant leading meetings, usually over several days
where staff identifies every touch, movement, contact, flow, etc. of the permit application intake
through issuance process and documents each (usually by writing each on a sticky note and attaching
them to a wall). Each item is then questioned as to the necessity of why the item is being performed. If
the item cannot be validated as either necessary or legally mandated, the item is deemed unnecessary
and eliminated. The process typically results in a 15%-40% reduction in workload.
It is obvious that a great deal of time and money has been used to implement the Energov and EPIC
systems. My limited observation of EPIC indicates to me that the implementation was intended to make
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applying for a permit as painless for the applicant as possible and to a great extent looks to have been
successful. This is particularly true given the challenges that Energov is well known for. While there are
no perfect permit systems in existence, Tyler’s Energov is well known in the building permit industry as
being particularly problematic. With adequate revenues, the problems eventually always come to a
resolution.
I’ve worked with several jurisdictions that have implemented Energov and one commonality seems to
be that the sales team makes promises that the technical installation team can’t keep or at least can’t
keep while staying within the contract budget. Typically, this results in added and unanticipated
expenditures after the system goes live. Additionally, there are always things that permit and IT staff
find they wished they had done differently. In conversation with building division staff there appears to
be some of the same angst in this regard as I’ve heard from several other jurisdictions.
There is always some level of ongoing customization with any permit system therefore there is always a
need for a revenue stream (in addition to annual maintenance charges) to pay for such customization.
It appears EPIC was designed to make permit application as easy as possible for applicants without
predefined “you can’t go to step B until you complete step A” types of requirements. While on the
surface this methodology seems like great customer service, it’s counterproductive by putting additional
work on the permit clerks so actually results in a delay in permit processing. A better methodology is to
utilize drop down pick lists and require applicants to choose the appropriate information from each pick
list before they can move on to the next item. Doing so will reduce the workload of the permit clerks
and keep the “chess clock” on the applicant’s side until the application is completed. If that change is
decided to be implemented, it with create a need for significant additional revue for the vendor.
Another item noted is that there does not appear to be a user-friendly method for applicants to access
GIS data via EPIC or Energov. I’ve heard this compliant from several developers.
The building chief (building official is the position title used in the International Building Code (IBC)) from
what I’ve learned has had no participation in national code development. The same holds true for the
assistant building chief. Each year, code change proposals are sent to the appropriate International Code
Council (ICC) committee for consideration. The committees meet in the spring where testimony both
pro and con are put under consideration and at the end of about a one-week session, the committees
will send their recommendations forward for ICC staff to compile.
In the fall of each year, ICC holds their annual business meeting (ABM) where the full membership will
listen to testimony both pro and con and then vote whether to accept the committee’s
recommendations. The ABM’s are rotated around major mainland cities each year. These 11-day
meetings not only give the building chief knowledge of what code changes will be in the next code cycle
but also provides the building chief the knowledge of the reason behind each change. That knowledge
gives them the ability to properly interpret the code changes as well as the ability to bring that
knowledge back to the jurisdiction and pass it along to building division staff.
While travel around the nation is expensive, it’s typically far less expensive than sending multiple staff to
mainland training events. The current building chief has never been to one of these events.
Recommendations:
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• Implement a technology fee to pay for enhancements to Energov. These fees are not unusual
(typically around $25.00 per permit).
• Investigate increasing plan review fees to industry standard (65% of the permit fee).
• Conduct Lean Process Improvement training for all building division staff
(https://www.lean.org/https://www.lean.org/). This will necessitate hiring a consultant
proficient in the Lean process.
• Provide Public Duty Doctrine training for all building division staff. This can usually be facilitated
by the jurisdiction’s legal staff.
• Investigate allowing building plan reviewers performing structural review for simple projects.
• Investigate allowing building inspectors to perform combination inspections.
• Look into third-party plan review services.
• Define by ordinance what constitutes a complete permit application.
• Assuming that data connectivity is generally available across the jurisdiction, eliminate the need
for the permit applicant to come back to the permit center to obtain a permit placard. Instead,
provide access to be able to print and post the permit and an inspector to access permit
information remotely when they feel necessary.
• Provide budgetary support to allow the building chief and assistant building chief to participate
in the ICC Committee Action Hearings (spring meeting) and the ICC Annual Business Meetings
(fall).
• Eliminate the use of “Sessions” in the Bluebeam Revu process. The same result can be achieved
provided both Hilo and Kona are on the same Local Area network (LAN) without the inordinate
amount of work setting up a “session” each review creates. Most jurisdictions where all review
staff are on the same LAN have stopped using sessions.
• Provide additional GIS integration within EPIC to automatically let the permit applicant know if
the subject property has restrictions such as flood plain or geologic hazards.
Tyler J. Benner
County Auditor
County of Hawaiʻi Office of the County Auditor 120 Pauahi St., 309 Hilo, HI 96720 808.961.8386 www.hawaiicounty.gov
The Office of the County Auditor is tasked with promoting accountability, fiscal integrity, and openness in local government. Our work is intended to assist County government in its management of public resources, delivery of public services, and stewardship of public trust. Copies of this audit report can be obtained by contacting the Office of the County Auditor or visiting our website: https://www.hawaiicounty.gov/our-county/legislative/office-of-the-county-auditor/audit-reports