Greg Redeker on Responding to Staff Comments

Greg Redeker, Real Estate Manager, Stott Outdoor

Greg Redeker is a Real Estate Manager for Stott Outdoor Advertising.  Greg spent 20 years working for local government, most of that time as an urban planner.  He also served as a zoning administrator and was lead author for a comprehensive sign ordinance update.  Today Greg shares some tips for responding to staff comments after you’ve submitted a permit application.  He can be reached at gredeker@stottoutdoor.com.

  1. There’s a reason they ask for a lot. In many states, the local planning department can’t ask for anything beyond what they ask for initially, with limited exceptions.  This is a good thing, as it prevents the planning office from continually “discovering” new deficiencies in an application, effectively stalling your project’s journey towards a public hearing.  As a result, the initial status letter from the jurisdiction (also called an “incomplete” letter) may seem unreasonably long, and include a number of things that leave you scratching your head.  The local agency may be unsure whether they’ll actually need a particular bit of information, but if they don’t ask for it now then they can’t ask for it later.
  2. Not every request is written in stone. Seasoned applicants have learned that many items listed in that initial letter may not be needed, or that a particular issue can be addressed in a different way.  As noted in my article on working with city permit staff, the planner processing your application may have less experience and/or not be receiving the best direction from their higher-ups.  Some of what they’re asking for may be based on an incorrect understanding of your proposal, an incomplete grasp of available options, or mistaken assumptions about which regulations apply to your project.  Gently probe and push back a bit to help them clarify what they really need.  Be prepared to offer solutions which they may not have considered.
  3. Respond to the status letter in writing. Whether in an e-mail or a letter, use this opportunity to list all of the things you’re providing.  Connect each revision or new piece of information to specific requests in that initial status letter.  Recap any discussions you may have had, including resulting modifications to the list of materials needed, e.g. “Please find enclosed two visual simulations depicting the new sign as viewed from the adjacent highway.  As agreed in our meeting last Thursday, the other four visual simulations requested in the initial status letter (including the two nighttime simulations) are not needed at this time.”
  4. Everything you submit is a public record. As a government employee, one of the best pieces of advice I received was to never put anything in an e-mail that you didn’t want to see on the front page of the newspaper.  The same goes for permit applicants – every letter and e-mail that you submit to the planning office is a public record.  Act professionally and communicate accordingly.  And if you need to discuss a sensitive matter, pick up the damn phone.
  5. Focus on what you really want – an approval. At the end of the day, all you need is for your application to make it to the top of the stack, and for staff to make a favorable recommendation to the decision-making body.  Swallow your pride and refrain from speaking or acting in a way which doesn’t bring you closer to that goal.

 

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