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FINAL REPORT
City of Glendale
2024 ECONOMIC DEVELOPMENT PERFORMANCE AUDIT
October 30, 2024
Moss Adams LLP
999 Third Avenue, Suite 2800
Seattle, WA 98104
(206) 302-6500
Economic Development Performance Audit Draft Report
FOR INTERNAL USE OF CITY OF GLENDALE ONLY
Table of Contents
Executive Summary 1
A. Risk Rating Definitions 1
B. Statement of Compliance with GAGAS 1
C. Conclusions 2
Detailed Report 5
A. Background 5
B. Objectives 5
C. Scope and Methodology 5
Findings and Recommendations 7
A. CVB Funding and expenditure compliance 7
B. Development Agreement Management 12
C. Special Event Processes 16
Appendix A: Special Events Processing Peer City Benchmarking
Matrix – July 2024 34
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EXECUTIVE SUMMARY
The City of Glendale (City) engaged Moss Adams LLP (Moss Adams) to conduct a
performance audit of the City’s Economic Development Department (EDD, the
“Department”). EDD has undergone significant changes since 2023, including a
reorganization of the Convention and Visitors’ Bureau (CVB) and Special Events team,
alongside leadership transitions.
Our objectives for this performance audit were:
• How effectively is EDD collecting and expending CVB revenues to ensure compliance with its
taxes and fees?
• To what extent do contract management practices meet key regulatory requirements and align
with best practices?
• How efficient and effective are special event application processes?
To complete this performance audit, Moss Adams analyzed EDD’s contracts, staffing, and
tax revenue between July 2023 to October 2024. Our peer benchmarking for development
agreement management included three cities in the region, while peer benchmarking for
special events processing included three cities of comparable size in California. We also
incorporated industry best practice research in our analysis to inform our recommendations.
The following definitions guided our risk rating:
• Low risk: Findings with a low likelihood of causing significant impact but still warrant attention to
improve efficiency, effectiveness, and service delivery.
• Medium risk: Findings with a moderate likelihood of causing negative impact if left unaddressed.
These should be prioritized for corrective action to improve performance.
• High risk: Findings with a high likelihood of causing significant negative impact (e.g., post a
threat to achieving organizational objectives) if not promptly addressed.
We conducted this performance audit in accordance with generally accepted government
auditing standards (GAGAS). GAGAS requires that we plan and perform the audit to obtain
sufficient, 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.
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The following findings compare EDD’s CVB funding and expenditure compliance,
development agreement management, and special events processes in relation to peer city
and industry best practices. Recommendations are intended to help EDD develop efficient
and effective practices to support the City’s economic growth and tourism.
FINDINGS AND RECOMMENDATIONS
CVB Funding and Expenditure Compliance
Low Rated Finding
1. Finding Unlike peer cities, the City does not have an ordinance or other guidance
defining or restricting the use of collected bed taxes.
Recommendation The City should develop an ordinance, and corresponding policies and
procedures, to provide clear guidance on how collected bed tax revenue should
be used, including whether revenues will be fully or partially restricted to
furthering local tourism.
Low Rated Finding
2. Finding Unlike peer cities, EDD does not issue a Convention and Visitors Bureau (CVB)
Annual Report, which limits how effectively it communicates tourism demand
and impact to the community.
Recommendation EDD should develop a CVB Annual Report to share progress toward its
strategic plan and key results. This report should include details, such as visitor
statistics and local impact, to help inform the community on tourism impacts on
the local economy.
Development Agreement Management
Medium Rated Finding
3. Finding The City does not have a designated person or process for development
agreement monitoring, which presents risk that developers and the City may
not be upholding the terms of the agreement to support community objectives.
Recommendation The City should designate development agreement monitoring to an employee,
or team of employees, and establish a framework for ongoing monitoring.
Special Events Processes
Medium Rated Finding
4. Finding With the exception of the Fire Department, the City does not consistently
complete inspections for the events they authorize to ensure compliance with
issued permits and promote safety for eventgoers.
Recommendations EDD should have designated special events employees ensure that all
inspections are completed prior to the event opening for attendees.
Additionally, the City may consider factoring the price of inspections into
the application process to reframe the inspections as paid for instead of an
additional cost to avoid.
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FINDINGS AND RECOMMENDATIONS
Medium Rated Finding
5. Finding While EDD has a Special Events Program Manager to serve as a single point
of contact for special event customers and internal coordination, the City lacks
a policy to standardize which departments must review applications, which
makes processing event application reviews more difficult.
Recommendations In collaboration with other city departments, EDD should develop a policy
that provides guidance on what elements of an event trigger additional
review steps and ensure all employees involved in the review process are
aware of and understand the guidance.
EDD should continue to use a designated person(s) to serve as the
primary point(s) of contact for event organizers and liaise directly with
relevant departments to ensure appropriate approvals are in place prior to
the event occurring.
Medium Rated Findings
6. Finding The Special Events Master Application (SEMA) and application submission
process lacks clarity, price transparency, and does not have controls in place to
catch errors or prevent incomplete submissions.
Recommendations EDD should develop internal policies and standard operating procedures
that clearly define special events and associated fees and incorporate
them into the SEMA and application process.
EDD should continue to adjust the SEMA and submission process to help
improve clarity in the application process for customers and help the City
detect issues with applications earlier.
Low Rated Finding
7. Finding EDD uses multiple systems to facilitate special event application reviews, which
creates inconsistencies in the review process timelines, adds complexity to the
process, and potentially limits the completeness of record retention and
performance tracking.
Recommendations The City should continue to work on implementing Clariti as its permitting
system for intaking applications, administering reviews, and documenting
approvals for events, and ensure that all stakeholders in the review
process and the customer have adequate access to it.
To influence customers to be more consistently timely with their
submissions, the City can introduce a fee schedule that increases
application fees as the event application is submitted closer to the start of
the event.
Low Rated Finding
8. Finding The City’s definition for special events is broad and focused on events held on
city-owned property. This can lead to excess work and elongated processing
timelines for small-scale community events, such as local shop tabling, tree
lots, and pumpkin patches; and less comprehensive reviews for private events.
Recommendations The City should update the municipal code to ensure event hosts properly
permit their events regardless of location, and also differentiate small
community events from special events to expedite their review and
approval.
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Although the focus of this performance audit was to identify opportunities for improvement, it
is important to note the areas of commendable operations. The Department should be
commended for the following accomplishments:
• Strong Partnerships: The Department has strong ties with event hosts and supplies vendors
within the community, enabling it to regularly execute exciting, tourist-attracting events which
drives local economic growth.
• Adaptability: The Department has undergone many changes during recent years. Team
members collaborated well to balance workloads and responsibilities in order to continue City
operations and ensure safety in special events.
• Commitment to Improvement: Department staff and leadership were engaged in our
conversations and demonstrated a willingness to critically evaluate current practices.
We would like to thank EDD staff and leadership for their willingness to assist with this
project.
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DETAILED REPORT
Glendale, Arizona is located in Maricopa County, Arizona, and is home to approximately
258,000 residents. EDD works to attract and retain new and expanding businesses, while
also overseeing the Convention and Visitor’s Bureau (CVB), Special Events, and Arts &
Culture divisions.
The City has a thriving tourism industry and routinely hosts mega events such as the
Superbowl. This work is supported by the CVB and the special events team. The CVB is
responsible for marketing Glendale as a destination for tourism and hospitality, and partners
with local organizations to promote attractions, events, and amenities. The City collects a
bed tax of 7.9% on income from hotels and other short-term rentals to fund CVB and other
initiatives aimed at increasing tourism in the community. EDD’s special events team assists
with the coordination of special events, including accepting applications and working with
other City departments to issue permits for potential small and large-scale events.
The City also leverages development agreements to support its economic development
goals. A development agreement is a contract between a developer and the City that
outlines the terms and conditions for a specific development project, including areas such as
infrastructure investment, job creation, economic diversification, and community
enhancements. EDD works closely with the Development Services Department to negotiate
development agreements.
Overall, Glendale’s CVB, special events, and development agreements are core to the role
of EDD and intended to support a robust local economy.
Our objectives for this performance audit were:
• How effectively is EDD collecting and expending CVB revenues to ensure compliance with its
taxes and fees?
• To what extent do contract management practices meet key regulatory requirements and align
with best practices?
• How efficient and effective are special event application processes?
We performed the following procedures to obtain an understanding of EDD’s bed tax
revenue and CVB management practices, development agreement contract management
practices, and special events application process.
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• Interviews: We conducted interviews with staff from EDD, including representatives from the
CVB, leadership, and special events staff. We also interviewed the Development Services
Department Director, Development Services Permit Technician, and Fire Inspector to learn more
about development agreement monitoring and special event permitting and inspection processes.
• Document Review: We reviewed multiple documents, including but not limited to:
○ Organizational charts
○ CVB revenue reports, budget documents, market plans, and bed tax breakdown
○ Job descriptions
○ Lists of current contracts and 2023 special events
○ Special Events Master Application
○ For sampled special events, the application and issued permits
• Benchmark Analysis: To evaluate EDD’s comparative performance in special events application
processing, we met with various localities including the Town of Gilbert, Arizona and the
California cities of Santa Monica, Anaheim, and Pasadena to gather information on a range of
topics, including:
○ Special events definitions
○ Customer service points
○ Special events team staffing
○ Systems used
○ Special events review process
○ Review process timelines
Results from our special events benchmarking activity are summarized in Appendix A of
this report. We also compared publicly available information from regional cities to inform
our comparison for bed tax funding and CVB reporting.
• Industry Best Practice Research: Where possible, we conducted industry best practice
research to help inform our recommendations.
We worked with EDD personnel and leadership to obtain the most currently available
information and insights. The performance audit was conducted between March and
October 2024.
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FINDINGS AND RECOMMENDATIONS
1. Finding Unlike peer cities, the City does not have an ordinance or other guidance
defining or restricting the use of collected bed taxes.
Recommendation The City should develop an ordinance, and corresponding policies and
procedures, to provide clear guidance on how collected bed tax revenue
should be used, including whether revenues will be fully or partially
restricted to furthering local tourism.
Criteria
According to the Government Finance Officer’s Association (GFOA), cities that collect bed
tax revenue from hotels and other short-term rentals often have ordinances in place to guide
the use of these funds. This guidance outlines how a city should use bed tax revenue to
support the local economy and promote tourism. A well-designed policy promotes adequate
stewardship of collected funds and ultimately enhances transparency to stakeholders and
builds trust in the city’s commitment to responsible fiscal management.1
Arizona Revised Statute § 9-500.06 (2023) also provides guidance that if a tax is imposed
disproportionately on hospitality industry businesses, including hotels, motels, and short-
term rental properties, compared to other types of businesses in the city, then the revenue
from the tax must be used for promoting tourism.2 The statute goes on to indicate that
allowable expenditures for the promotion of tourism include:
• Sporting events and cultural exhibits
• Contracts between the municipality and a nonprofit organization for the promotion of tourism by
the nonprofit
• Developing, improving, or operating tourism-related attractions or facilities
Peer Analysis
Using publicly available information, we conducted peer city benchmarking and noted that
several cities of similar sizes within the vicinity of Glendale had guidance on how bed taxes
1 GFOA: Tourism and Lodging Tax
2 AZ Rev Stat § 9-500.06 (2023)
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should be used within city ordinances. The ordinances defined how each peer city should
expend their bed tax collected.
For example, Article IV Section 447 of Scottsdale’s municipal code specifies that 50% of the
revenue derived from the transit tax “shall be used for destination marketing to promote
tourism and 50% shall be divided among tourism-related event support, tourism research,
tourism-related capital projects, and other eligible uses as determined by city ordinance and
state law.” Additionally, the City of Peoria’s municipal code also indicates that 9% of all bed
tax proceeds will be credited to the tourism and event development fund.
Condition
Glendale does not have a city ordinance or other documented policies and procedures that
define how collected bed taxes should be used. While EDD employs its best judgment in its
use of funds and generally applies bed tax revenues to the CVB and tourism promotion,
leaders reported a desire for additional guidance to understand how to identify uses that aid
in economic development and tourism.
Tenured employees in the CVB indicated that previously there was some distinction on
whether CVB spend could occur within or outside the State of Arizona, although there is no
documentation that would indicate the need to differentiate between these activities.
Cause
Recent turnover among CVB employees and a lack of documented policies and procedures
has resulted in unclear expectations around the appropriate expenditure of bed taxes.
Interviewees reported current guidance from Glendale code is vague and does not help
them clearly delineate appropriate use of funds.
Effect
Not having a bed tax usage policy to guide a city on how to use the taxes it collects can
have a number of negative effects. Without a clear policy in place, there may be a lack of
transparency and accountability regarding how this tax revenue is used, which can erode
public trust and confidence in local government. Additionally, without a policy to guide the
use of these funds, there may be a risk of using bed tax revenue for purposes that do not
relate to tourism, which can have negative economic impacts on the local economy and
generally does not align with peer or industry practices.
Recommendation
The City should develop an ordinance that defines any potential restrictions or intended use
of collected bed tax dollars. This ordinance should be publicly announced to ensure full
transparency over the restrictions in place and to allow stakeholders to hold the City
accountable to its requirements.
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Following the approval of an ordinance that describes how bed taxes should be used, EDD
should develop policies and procedures that define allowable uses. An internal bed tax
usage policy should include the following elements:
• Strategic alignment: The City should be explicit about their goal to ensure that their use of bed
tax revenue is aligned with their broader economic development goals and priorities.
• Clear definitions: Funding sources of the bed tax and restrictions of its use should be explicitly
stated. This includes definitions of what is allowable and unallowable according to the restrictions
set forth in the ordinance.
• Fund oversight and management: A process should be established for requesting, reviewing,
and approving bed tax fund budgets and expenditures.
• Accountability: Mechanisms should be in place to ensure that bed tax revenue is used
effectively and efficiently. Managers should be able to demonstrate the impact of these funds on
the local economy, and bed tax fund policies should be accessible to employees and
stakeholders.
While available guidance governing the use of bed tax funds is limited and open to
interpretation, the City should clearly develop a policy to document their operating
parameters and ensure proper stewardship and transparency of the funds.
MANAGEMENT RESPONSE
Management Agreement Department leadership concurs with.
Owner CVB Administrator/Deputy Director of Economic Development
Target Completion Date June 30, 2025
Action Plan
Economic Development Deputy Director and CVB Administrator will work with
Budget and Finance and Legal to seek guidance on drafting an ordinance.
The CVB Administrator will utilize benchmark information to draft initial ordinance
and will provide proposed language to CMO, Legal and Finance for input.
A final draft of the ordinance will be presented to the City Council and will require
formal approval of the Council.
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2. Finding Unlike peer cities, EDD does not issue a Convention and Visitors Bureau
(CVB) Annual Report, which limits how effectively it communicates
tourism demand and impact to the community.
Recommendation EDD should develop a CVB Annual Report to share progress toward its
strategic plan and key results. This report should include details, such as
visitor statistics and local impact, to help inform the community on
tourism impacts on the local economy.
Criteria
According to Tourism Academy, destination marketing organizations (DMOs), such as CVB,
should develop and issue reports on visitor profiles, resident opinions, and economic impact
to help make informed decisions and develop effective strategies.3
An effective annual report for a CVB will promote transparency, accountability, and
stakeholder engagement. By providing key performance metrics, financial information, and
highlighting accomplishments and challenges, an annual report can help build trust and
confidence in the CVB and demonstrate the City’s commitment to responsible fiscal
management and economic development within its community.
Peer Analysis
Cities of similar sizes and within the same vicinity of the City had CVB annual reports
available on their websites for the public to access. For example:
• Experience Scottsdale, the City of Scottsdale’s DMO, issues a report that includes an
assessment of hotel performance, local economic impact, return on investment for advertising,
revenue and expenses, marketing activity, key initiatives, social media reach, communications
activity, convention activities, tourism, and member and partner development with local
organizations.
• Discover Gilbert, the Town of Gilbert’s DMO, also produces annual tourism data such as the
number of visits, visitor profiles, lodging bookings and revenues, contribution to the local
economy, and progress toward its strategic plan goals.
Condition
EDD has not historically issued a CVB annual report. As of our August 2024 discussions,
the Deputy Director of EDD is reportedly working on developing reporting templates to
facilitate regular CVB reporting moving forward.
3 Three Essential Reports Every Destination Marketing Organization Needs
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Cause
The CVB has experienced a reorganization and employee turnover in recent years. While it
can be difficult to prioritize the development of this reporting given recent reorganization and
process changes, such reporting is imperative to share the result and impact of tourism-
related activities in the City.
Effect
Not having annual reports for CVB operations can have a number of negative effects.
Without an annual report, there may be a lack of transparency and accountability in the
CVB’s operations, which can result in questions on tourism trends, return on investment,
and the impact of tax dollars on the local economy. When this information is unknown and
not shared, it can limit the City from soliciting additional hospitality and service businesses to
help support growth in tourism.
Additionally, without an annual report, stakeholders may not have access to key
performance metrics or financial information, which impedes their ability to evaluate the
effectiveness of the CVB’s marketing and promotional efforts. This can make it difficult to
identify areas for improvement or to make informed decisions about future investments in
the local tourism industry. Engagement with stakeholders may also be limited, impeding
opportunities for collaboration and partnership building.
Recommendations
EDD should continue to develop reporting templates and capabilities to ensure that progress
toward its strategic plan and key results, such as visitor statistics, is visible to stakeholders,
and to help inform the community of its activities and aspirations.
As EDD develops reporting processes that contribute to an annual CVB report, it should
incorporate the following:
• Performance metrics: The annual report should include key performance metrics that measure
the effectiveness of the CVB’s marketing and promotional efforts, such as the number and type of
visitors, hotel occupancy rates, and economic impact.
• Financial information: The annual report should include financial information, such as the CVB’s
budget, revenue, and expenses, to provide transparency and accountability to stakeholders.
Many DMOs also report the direct and indirect impact of tourism, such as through local
employment and additional tax revenue. This information can be used to help spur additional
investment opportunities for the City.
• Accomplishments: The annual report should highlight the CVB’s accomplishments over the past
year, including successful events, marketing campaigns, and other initiatives.
• Challenges and opportunities: The annual report should identify challenges and opportunities
facing the CVB and the local tourism industry, and outline strategies for addressing these issues.
• Stakeholder engagement: The annual report should demonstrate the CVB’s engagement with
stakeholders, including local businesses, residents, and tourism organizations, and should
highlight any partnerships or collaborations that have been established.
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With templates to facilitate reporting, the City can increase its public serving perception and
make itself as a marketable, conscientious business partner and tourism destination.
MANAGEMENT RESPONSE
Management
Agreement Department leadership concurs with this recommendation.
Owner CVB Administrator
Target Completion
Date August 31, 2025
Action Plan
When the CVB division was moved over to EDD, leadership immediately
acknowledged the need for an Annual CVB Report. Prior to the initiation of this
audit, department leadership had begun developing the template for an annual
plan. EDD is currently recruiting a CVB Administrator that will be responsible for
development and execution of the CVB Annual Report.
In the interim, the Deputy Director of EDD will begin developing this year’s
inaugural plan with the intention of the Administrator presenting the draft plan to
city leadership after the closing of the fiscal year.
Once the report is provided to city leadership, it will be distributed publicly via the
CVB website.
3. Finding The City does not have a designated person or process for development
agreement monitoring, which presents risk that developers and the City
may not be upholding the terms of the agreement to support community
objectives.
Recommendation The City should designate development agreement monitoring to an
employee, or team of employees, and establish a framework for ongoing
monitoring.
Criteria
The Government Finance Officer Association (GFOA) indicates that government officials
must ensure proper administration of development agreements to ensure objectives
established in the agreement are accomplished.4 They recommend an approach that
includes monitoring performance milestones and compliance requirements, communicating
4 GFOA: Monitoring Economic Development Performance
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progress to City Council and stakeholders, and establishing safeguards to trigger early
detection of any problems that may require renegotiation or termination of the contract.
GFOA guidance recommends that cities identify staff capacities that will be needed to
properly monitor the various components of an agreement, which is likely to include
representatives from several departments including Economic Development, Development
Services, and Finance. In some cases, a third-party consultant may be engaged to support
monitoring activities.
Monitoring processes should encompass compliance requirements and the accomplishment
of goals, such as job creation, affordable housing production, or an increase in tax
revenues. Both of these components are important to ensure both parties are living up to
their stated obligations and to justify the incentives that were provided.
Peer Analysis
We conducted peer benchmarking and noted that cities of similar sizes and within the same
vicinity of the City had a single point of contact or lead within their economic development
departments that managed development agreements. Peers indicated that success factors
included clearly defined roles and responsibilities to facilitate the point of contact’s
ownership of each executed contract. Monitoring processes were typically designed to
incorporate review of regulatory compliance requirements and included internal control
procedures such as peer or supervisor review and signoffs to document their date of review.
Condition
Development agreements at the City can be entered into for a variety of reasons and a
variety of different sources. Some can be driven by economic development goals, housing
production, or driven by the City Manager’s Office. Under the current process, Economic
Development will email impacted departments the development agreement. For example,
Development Services manages the calculation and collection of development fees and
would apply waivers or other incentives that are agreed upon in the contract with the
developer. Currently, the City does not appear to have a comprehensive repository of all
development agreements. However, an upcoming permit system change is anticipated to
assist with the tracking of development agreements moving forward.
The City does not have a designated person or process for development agreement
monitoring, which presents risk that developers and the City may not be upholding the terms
of the agreement to support community objectives. In practice, the Economic Development
employee who helped negotiate the development agreement takes on monitoring
responsibilities, such as ensuring the building is complete by a certain date or confirming
every few years that the developer has a certain number of employees. However, the City
does not have a system in place to track the requirements or performance against these
metrics. Instead, City staff report that Excel spreadsheets are generally used to track
compliance and achievement of stated goals.
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Cause
Development agreements can be complex and last for 20 or more years. There are several
departments that could be involved in monitoring efforts, and due to the long-term nature of
these agreements, employee turnover impacts whether monitoring is consistently taking
place. After the recent EDD restructuring, there was an elevated level of employee turnover,
which could also interrupt monitoring practices.
Effect
Without a designated employee and process to provide oversight of development
agreements, the City may encounter non-compliance and other issues. Poor development
agreement management can make it difficult to enforce development agreements and
ensure that they are meeting their intended goals. Developers may not be providing what
was required of them per the agreement and may cause the City to miss out on community,
economic, and tax revenue benefits.
By relying on individual employees to monitor development agreements that they were
involved in negotiating, each new agreement results in additional workload for City staff.
Employee time is then spent on monitoring contracts rather than bringing in additional
businesses to support the local economy. There is also a risk that employees do not hand-
off the development agreements they are responsible for when leaving their position.
Recommendation
The City should designate development agreement monitoring to specific employees and
establish a framework for ongoing monitoring of outstanding agreements. As the City
develops a system to support its development agreement management practices, it should
also consider the appropriate party to enforce compliance. Due to the broad nature of
developing agreements, it is possible to incorporate enforcement responsibilities into a
variety of city functions, including tax and licensing, code enforcement, the Police
Department, or even the EDD. Overall, having a designated person and process for
monitoring development agreements is essential for ensuring compliance, mutual
accountability, and achieving economic development goals. The employee or team of
employees should be assembled based on the specific terms within each development
agreement that is negotiated.
Monitoring development agreements should focus on compliance and accountability, and
can include the following:
• Defining monitoring requirements: Cities should define what actions and performance they will
be monitoring based on the terms included in each development agreement. This can include
outlining the goals for the development and what supporting documentation will be required to
demonstrate that the developer has complied. In some cases, the City may also need to take
certain actions to help achieve a project’s goals, so the City should also define what it is
responsible for completing.
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• Accountability: Cities should have a designated person or team responsible for monitoring
development agreements and should establish clear lines of accountability for ensuring
compliance with these agreements. As noted previously, there may be individuals from other city
departments who should be engaged in monitoring processes.
• Timeliness: Cities should establish a process for monitoring development agreements that is
timely and efficient, and that ensures that all parties are held accountable for meeting their
obligations.
• Transparency: Cities should make information about development agreements and their
monitoring process available to the public to promote transparency and accountability.
• Enforcement mechanisms: Cities should establish enforcement mechanisms for addressing
non-compliance with development agreements, including penalties and other consequences for
parties that fail to meet their obligations.
By establishing clear criteria for monitoring and enforcing development agreements, EDD
can help ensure that these agreements are effective in promoting the local economy and
community.
MANAGEMENT RESPONSE
Management
Agreement EDD leadership partially concurs with the recommendation.
Owner EDD, Budget & Finance, Development Services, and possibly the City Attorney’s
Office
Target Completion Date September 30, 2025
Action Plan
EDD leadership agrees that designated contract management staff is an absolute
necessity. However, EDD staff should not be responsible for this function as
contract monitoring is for terms that are not administered in the economic
development department – i.e. fee waivers, infrastructure credits, etc. EDD should
not be disincentivized to negotiate and execute development agreements and be
responsible for contract monitoring of terms that are administered by other city
departments. EDD leadership will work with the departments listed above to
determine where this position should reside, how it should be funded, and who
will include it in their FY26 budget requests to City Council. If approved for
funding, the appropriate department will begin recruiting for the position to be
filled in early FY26.
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4. Finding With the exception of the fire department, the City does not consistently
complete inspections for the events they authorize to ensure
compliance with issued permits and promote safety for eventgoers.
Recommendations
A. EDD should have designated special events employees who ensure
that all inspections are completed prior to the event opening for
attendees.
B. Additionally, the City may consider factoring the price of
inspections into the application process to reframe the inspections
as paid for instead of an additional cost to avoid.
Criteria
EDD should have a process to ensure that all necessary inspections are conducted by the
relevant departments that reviewed the application and issued a permit for an event before
the event starts. Event hosts should prioritize rectifying any issues noted during event
inspections before the event opens to the public.
Peer Analysis
Peers reported that inspections are typically coordinated by an inspector from the reviewing
department with the event host. Inspections are collaborative in nature, and inspectors
generally work with the event host to resolve breaches or find suitable alternatives, as
necessary, to allow the customer to have the event they envisioned without compromising
public safety.
Condition
The City does not consistently complete and document all the necessary inspections for the
events they authorize. While the fire department inspections are regularly completed, we
received reports that inspections from other departments are occasionally not completed or
that inspectors may identify potential hazards, but allow the event to continue. In one
notable example, an inspector identified a generator that was incongruent with expectations
set forth in the application. The inspector allegedly tagged the generator during their
inspection to reduce liability to the City, but the event continued, on which presented a
safety risk to attendees. Upon further review, City staff reported being unable to find records
for inspections they were involved in completing, suggesting that inspections were being
completed prior to events but were not documented. Incomplete documentation of
inspections that were completed can also pose risks and potential liability to the City,
particularly if the inspection had identified safety issues but was not documented.
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Cause
Once applications receive the final authorization, customers are responsible for coordinating
inspections with the appropriate department(s) with no accountability built into the process
by the City. Event hosts may be disincentivized from completing inspections since they are
assessed separate fees and could delay event opening if issued are identified.
As noted previously (see the Event Review Process Inconsistencies and Systems
Environment and Monitoring Application Reviews sections) the City faces challenges with
monitoring applications and to balancing the administration of inspections with the goals of
providing high-quality customer service.
Effect
Poor adhesion to the inspection process can lead to increased risks to public safety should
an event go live without the proper inspections ensuring that adequate safeguards are in
place. Events that are held without the proper inspections and related documentation can
lead to liabilities for the City and may warrant increased spending on insurance to
compensate for gaps in adequate safeguards.
Recommendation
The City should develop a process for inspections and assign this review responsibility to a
designated special events employee to ensure that all required inspections are identified
and completed. A well-designed process will typically include the following:
• Inspection coordination: The special event department point of contact for the event should
coordinate with relevant departments to ensure inspections are conducted in a timely and efficient
manner.
• Final spot check: The reviewing employee should verify the event file contains all necessary
completed permits and inspections before they allow the event to launch.
• Emphasis on importance: The special event department should communicate with event
organizers to ensure that they are aware of the inspection requirements, timelines, and
consequences for failure to conduct and pass the necessary inspections, and to provide guidance
and support as needed.
• Enforcement: The City should have mechanisms in place to enforce compliance with inspection
requirements, including penalties for non-compliance escalating to ceasing a live event.
Overall, having a process for inspections is essential for ensuring that events are safe, well-
managed, and do not pose a risk to public safety. By coordinating with relevant
departments, communicating with event organizers, and enforcing compliance with
inspection requirements, EDD can help ensure that events are successful and contribute
positively to the community.
To reduce barriers that event organizers may face to conducting the necessary inspections,
the City may consider factoring the price of required inspections into the application process.
By reframing the inspections as paid for instead of an additional cost to be incurred after
approval for the event is obtained (and that can be avoided), the City can emphasize a
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shared concern and commitment to public safety shared between the City and the event
organizer. In doing so, the City should ensure to communicate to applicants that prices
indicated early on in the application process are estimated, and will require the a complete
review before fully determined.
MANAGEMENT RESPONSE
Management Agreement Division leadership concurs with the recommendation.
Owner Special Event Administrator/Economic Development Deputy Director
Target Completion Date September 30, 2025 (pending ability to assign/gain FTE for this purpose)
Action Plan
With the high volume of special event applications received by the division and
the unique intricacies that differ with every application, a dedicated member of the
Special Events team should be assigned to oversee the review/inspection
process for all applications – additionally we would support exploring a fee
structure for this purpose. Department and Division leadership will continue to
lead a cross-departmental working group to overhaul and streamline the event
application review/inspection process including internal and external
communication oversight.
Department leadership will evaluate opportunity to assign/gain FTE specifically for
this purpose due to the high volume of applications and extensive follow up that
all applications require.
Department leadership will provide a proposed plan to city leadership for staffing
this need.
5. Finding While EDD has a Special Events Program Manager to serve as a single
point of contact for special event customers and internal coordination,
it lacks a policy defining which departments must review applications.
This presents challenges in efficiently processing event application
reviews.
Recommendations A. In collaboration with other city departments, EDD should develop a
policy that provides guidance on what elements of an event trigger
additional review steps and ensure all employees involved in the
review process are aware of and understand the guidance.
B. EDD should continue to use a designated person(s) to serve as the
primary point(s) of contact for event organizers and liaise directly
with relevant departments to ensure appropriate approvals are in
place prior to the event occurring.
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Criteria
Special event hosts should have access to City staff who will help them understand the
special event application process, assist them in providing the adequate documentation, and
provide customer service from the beginning of the application process through to the point
of approval. A high degree of service is important to ensure that customers feel comfortable
with the process, understand what expectations there are, and feel enabled to bring their
event ideas to fruition.
Having one person take ownership of each application to liaise with necessary reviewers
across the City as well as support the customer is essential in a seamless customer
experience. It also supports the application review process and helps ensure each
application is adequately reviewed by the appropriate party to minimize risk to the City.
Peer Analysis
Each of the four localities we benchmarked had an individual who served as a single point of
contact for special event applicants. These individuals helped usher each application
through the necessary reviews, which are determined by the application process. Peer cities
designed an application process and supporting informative documents to help the customer
and staff to understand which reviews are necessary. Representatives at each peer location
highlighted that, while this approach can sometimes increase review times, particularly for
first-time applicants, it overall proved effective in minimizing confusion for the customer and
preventing the customer from being overwhelmed from communication from various
departments.
Condition
The City pairs a Special Events Program Manager with a representative from the
Development Services department to limit the points of contact for special event customers
and to assist internal coordination of application reviews. However, limited guidance over
specific review requirements prevent internal staff from operating as efficiently as possible.
EDD does not have a policy or other guidance to standardize which departments should be
involved in a special event application review. Currently, Development Services staff review
submitted applications and work alongside the Special Events Program Manager to combine
their best judgement and experience to route an application to the appropriate
department(s) for review, either through the Hansen system or email. Once reviewed,
documents are aggregated for archival in the City’s Cerberus recordkeeping system. Due in
part to system limitations and difficulties in obtaining complete application documents from
event organizers, staff occasionally face challenges in tracking application progress and
keeping application reviews aligned with timeline expectations.
The Special Events team reported it is collaborating with partner departments involved in the
application review process to reach a mutual understanding and develop clearer guidelines
on what elements trigger additional review steps. We reviewed emails between
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Development Service Representatives and departments to clarify the need for review for
various events, including block party extensions, food trucks, and valet services.
Currently, staff in the Development Services Department serve as the last department
review step in the special events application review process. However, a comprehensive
application review is not explicitly designated to EDD. As a result, events are not
consistently vetted for the full suite of department reviews before a final approval is
communicated to the applicant.
Cause
The City uses an ad hoc approach to applications because of the many aspects that can
determine what reviews are required for an application and differences in interpretation.
Reviewing departments may not consistently document or communicate that they have
completed their review for an application, regardless of whether further action is necessary
to meet City standards. The process requires email communication to bridge gaps due to
the lack of integration between the Hansen and Cerberus systems as well. Processing
timelines regularly fluctuate based on how organized, timely, and familiar the customer is
with the application process. Because staff manually track application progress in disparate
systems, it is difficult to identify potential inconsistencies and track completion of application
permitting.
Effect
Limited guidance and a lack of a standard review process can detract from the level of
service EDD can provide. Customers can be confused throughout the process or unaware
of the status of their application. For example, applicants may not know when they are
missing documentation or not providing complete documentation. This causes further delays
and puts additional strain on EDD staff operating to stay compliant with processing
timelines. In the long-term, poor customer experience can lead to a public perception that
EDD is disorganized and unable to deliver the necessary degree of service, which can
dissuade future events from being submitted.
Ad hoc application reviews may result in some applications not being timely reviewed and
regularly tracked. Staff may not be fully aware of the internal reviews and approvals that
were required, making it difficult to determine whether an application has been fully
completed and the final permit is ready to be issued. A lack of a standardized review
processes creates risks that either (1) EDD is involving too many departments and operating
inefficiently, or (2) that too few departments are involved, and that safety concerns are not
appropriately addressed a result.
Combined with a lack of a single responsible party for any one application, some reviews
that are ready for next steps may become bottlenecked. In these scenarios, EDD would
need to assign high urgency to the application to help the customer host their event on time.
This practice undermines efforts to instate standard operating procedures, which can result
to disrupted workflows and furthers process inconsistencies and confusion.
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Recommendation
In collaboration with other City departments, EDD should develop a policy that provides staff
guidance on which elements of an event trigger additional review steps. Although each
event may differ and require EDD staff to apply professional judgment, the City should have
high-level checklists available to understand the rationales behind the reviews and
standardize event reviews to the extent possible. Once developed, EDD leadership should
ensure all employees involved in the review process are aware of, have access to, and
understand the guidance.
EDD can help the implementation of a revised review and approval process by designating
a person to be responsible for managing and monitoring each application from start to finish.
This person should be the primary point of contact for the event organizer submitting the
application and liaise directly with relevant departments to ensure appropriate approvals are
in place prior to the event occurring. Equipping this individual with the appropriate checklists
and other materials and policies to reference can shorten the amount of time necessary to
train them. As the employee gains mastery over the review flowchart, it will be important to
ensure any one-off scenarios deviating from typical applications are worked out and
incorporated into updated policy guidelines for future considerations.
MANAGEMENT RESPONSE
Management
Agreement Division leadership concurs with the recommendation.
Owner Special Events Administrator/Economic Development Deputy Director
Target Completion
Date September 30, 2025 (pending ability to assign/gain FTE for this purpose)
Action Plan
Department and Division leadership will develop a policy and relevant
guidance/checklists to outline and standardize event reviews and approvals
throughout the process. A designated person will be assigned to monitor event
applications from start to finish, as well training departmental personnel across
the city on the process and required documentation.
Department leadership will evaluate opportunity to assign/gain FTE specifically for
this purpose due to the high volume of applications and extensive follow up that
all applications require.
Department leadership will provide a proposed plan to city leadership for staffing
this need.
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6. Finding The Special Events Master Application (SEMA) and application
submission process lacks clarity, price transparency, and does not
have controls in place to catch errors or prevent incomplete
submissions.
Recommendations A. EDD should develop internal policies and standard operating
procedures that clearly define special events and associated fees
and incorporate them into the SEMA and application process.
B. EDD should continue to adjust the SEMA and submission process
to help improve clarity in the application process for customers and
help the City detect issues with applications earlier.
Criteria
The City’s special event application helps customers understand the expected
documentation for the event they desire to host and provides a high-level understanding of
the review process. The process to submit applications should feature pricing transparency
and be designed to prevent incomplete or incorrect applications from being submitted to
create efficiencies for staff, and ensure effective use of staff across the other City
departments participating in the review process.
Peer Analysis
All peer locations aspired to make their event application process as seamless as possible
for the customer. Commonly, they featured succinct applications that incorporate a high
level of detail to explain the overall application process and highlight key items that
determine review factors and what documents are expected to be submitted. Of particular
note, the Anaheim special event application includes the use of symbols and a key to define
them to indicate which city divisions will be reviewing specific event types or event elements
like tents, food concessions, and games. Similarly, the Santa Monica special event permit
application imbeds application fees for each activity permit or structure for an event.
Condition
EDD provides a SEMA form for event organizers to complete and submit through their
online Jotform portal. Along with completing the form, the customer is responsible for
describing their event, providing a site map, indicating key elements of their event (such as
the inclusion of a tent, open flames, and the provision of food or alcohol), and providing the
correct supporting documentation for City review and approval. The process involves
multiple layers of manual input and uploading, and often results in confusion and
downstream challenges that require back-and-forth communication with departments and
customers to resolve.
There are a number of factors that make understanding the special events application
review process difficult to understand for reviewers and customers alike including:
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• The directions available on the SEMA state that all events require the submission of a
comprehensive site plan. However, the application template does not provide information about
the site plan, and instead instructs the applicant to visit a website for additional information.
• Team members responsible for the intake of applications require additional support to understand
events and determine which permits or supplemental documentation may be required for each
event characteristic.
• Reviewers in other departments are reportedly not consistent in what is required for their review,
due in part to differences in interpretation of available guidance. For example, an event on private
property might be interpreted by some department reviewers to require a traffic control plan.
However, this may not appear reasonable to the event host or other reviewers, as it is reasonable
to expect that any event will generate or otherwise impact traffic.
• Inconsistencies in determining which additional documents are needed for partner department
reviews contribute to a cumbersome review process as well. Occasionally, EDD may need to
pause their application reviews to request additional documents from the applicant. Because this
aspect of event reviews involves staff in partner departments which have their own, separate
workloads, this ad-hoc approach to reviewing event applications limits the City’s overall efficiency.
• The SEMA asks customers to complete the event application process with a baseline
understanding instead of including the process logic within it. It asks customers to describe and
self-select what is required for a complete application review instead of guiding them through the
process.
• Instructions and additional information to guide customers through their use of the SEMA are
dense and not centralized within the application. The Special Event Guide and FAQ and the
SEMA are 7 and 6 pages long, respectively, but are both needed for understanding the
application process.
• The SEMA asks the customer to describe their event, which adds another layer of confusion, as
customers may interpret or label their event differently.
• The submission portal allows customers to submit incomplete applications. The portal has
customers indicate whether they are including supplemental forms. However, this might not be
helpful, particularly when customers may be confused and do not fully understand what
supplemental forms they should be completing.
• The submission portal only includes one upload step for all required and supplemental forms and
applications. This means customers could indicate that they included a supplemental form (e.g.,
pyrotechnic permit application), yet be allowed to submit their application without it.
• The SEMA does not include applicable fees when describing elements of the review process,
such as for a fire department review of the site map, event inspections, and additional permits.
• The Jotform portal date input format allows customers to input wrong or invalid dates.
The Special Events team has reportedly started to develop a new application designed to
enhance user friendliness. We reviewed the revised, view only Jotform application, noting
the application was more dynamic. Notably, when selecting private property for the event
location, the form updated to prompt for and solicit a letter of owner authorization. Similarly,
applicant choices in the event activities and special circumstances sections provided
additional context and information for the applicant.
EDD leadership also reported that it is working to implement a new permitting system,
Clariti. As part of this process, stakeholders in the review process from all departments have
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been collaborating to more clearly define what information is required for each step of an
application review.
Cause
The City has experienced an increase in the number of special and mega events hosted in
recent years. Alongside these increases, there has also been turnover among EDD staff
who manage events. This turnover, alongside a lack of documented policies and
procedures, resulted in confusion in the event application process. Additionally, special
events are becoming more complex as the City transitions to hosting large-scale events
more frequently.
Effect
Customer confusion about how to appropriately complete the SEMA for their event and a
lack of controls to prevent errors and incomplete submissions early on add complexity and
time to the review process. Applications are regularly pushed back to customers for
additional documentation, shortening the remaining time available for the City to review the
full package submission. In light of tight turnaround times, EDD’s acute focus on customer
service to allow the customer to host their event as desired means it often employs an
urgent review for many applications. This practice introduces inconsistencies in review
procedures and is susceptible to potential errors.
Customers may complete the application process without being fully informed of the
expectation, and encounter sticker shock towards the end of the application process.
Elevated levels of confusion for customers can develop the perception that the process is
excessively complicated or that the City is disorganized. Altogether, the experience may
discourage applicants from finalizing the application or make them reluctant to host
additional events in the future.
Recommendation
EDD should develop internal policies and standard operating procedures that clearly define
special events and associated fees and incorporate them into the SEMA and application
process.
Additionally, as EDD iterates on its new SEMA, it may want to consider the following to
streamline the application process to improve clarity and transparency for the customer and
help the City detect issues with applications early on:
• The SEMA could be adjusted to have event categories instead of an open response description
for their event. This could help direct applicants to forms and applications (e.g., if they select the
event is outdoor and needs a tent or canopy, the form could explain that an additional fire permit
and inspection is required).
• The SEMA should include a section for the required site plan and include the sample site plan
that is found on the Special Event Document Center. The application package should also include
a customer directive and highlight key components of site plans that are required, such as the site
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boundary, locations of structures to be placed at the site, the dimensions of the proposed
structures, the intended parking area, and the designated area for use of utilities.
• The SEMA could incorporate associated fees for applications and additional permitting to further
increase transparency for the customer.
• The Jotform portal could be adjusted to have required fields and required uploads for each
element of the application, which can help customers better understand the full scope of the
application process. For example, the form could require customers to indicate that the special
event application is required, upload the required special event application, acknowledge that a
comprehensive site plan is required, upload the site plan in a separate line item, etc. Additionally,
the form could change the format of the date request to use a calendar to help customers verify
their dates.
Improving the SEMA will help promote customer clarity on application requirements and
promote timely review of more complete information to help special events run efficiently,
effectively, and safely. It will also be crucial for the City and its staff to achieve a uniform
understanding of document requirements and carefully vet applications for completion, to
avoid internal operational disruptions across partner departments to the extent possible.
MANAGEMENT RESPONSE
Management Agreement Division leadership concurs with this recommendation.
Owner Special Events Administrator/Deputy Director of Economic Development
Target Completion Date September 30, 2025
Action Plan
The EDD team has already been engaged in the process of overhauling the
SEMA. Division team has had multiple sessions with the Organizational
Performance team for process improvement. This exercise requires a significant
effort from all reviewing departments as each have specific requirements that
need to be captured through the application process.
The interdepartmental working group has also been exploring the fee structure
associated with special events. Department and Division leadership will continue
to lead a cross-departmental working group to overhaul and streamline the event
application as well as the review/inspection process including internal and
external communication oversight.
The group will collectively develop a fee schedule that will be proposed to city
leadership and will ultimately require Council approval.
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7. Finding EDD uses multiple systems to facilitate special event application
reviews, which creates inconsistencies in the review process timelines,
adds complexity to the process, and potentially limits the completeness
of record retention and performance tracking.
Recommendations A. The City should continue to implement Clariti as its permitting
system for intaking applications, administering reviews, and
documenting approvals for events. Additionally, the City should
ensure that all stakeholders in the review process have adequate
access to necessary information.
B. To influence customers to submit special event applications early,
the City should consider introducing a fee schedule that
incentivizes early submissions.
Criteria
An ideal permitting system can route applications to the necessary departments, fully
capture approvals, and facilitate timely communication between City departments and the
customer. Communications with customers should allow for the highest degree of
transparency in application status, progress, and fees.
The permitting system should also enable the City to comply with any regulations and
processing timelines, such as the municipal code Section 29.2-10d requirement to issue an
approval or denial within 10 days of receipt of an application. Ideally, the system would be
able to help the City identify when an extension is allowed and necessary, and help it track
extensions to ensure they remain prioritized and get processed timely within the five-day
extension allowance.
Peer Analysis
All peers shared their application review process is centered around a main permitting
system, and that email was used to supplement the review process as necessary.
Collaboration was a main theme among discussions, and peers highlighted that leveraging
their system to document all work relating to each application was beneficial for monitoring
outstanding applications.
Condition
EDD uses both the Hansen system and email to coordinate the review for event applications
across departments, because some key contributors in the review process do not have
adequate access to the Hansen system. The Special Events team aggregates
communications from departments within the Hansen system or from email correspondence
to the extent possible for retention in the Cerberus system. These practices can sometimes
bottleneck and be difficult to track, which can present inconsistencies or delays in the
application review process. The ad hoc review process is prone to added complexity, which
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can make retaining complete records difficult and limit opportunities to develop a
standardized review process and the efficiency of performance tracking.
We judgmentally sampled six events from a list of all special events held by the City during
the 2023 calendar year to evaluate the completeness of internal review processes and
documentation retention. Of the six events, none had enough documentation to evidence
EDD conducted a review to the extent expected.
Due to limited policy and procedure documents, or other review documentation, we were
unable to determine the appropriate level of review necessary for all six samples. However,
we noted that two of six samples had a copy of the customer receipt retained, which
indicated the review and inspection steps the applicant had paid for. Based on this
information, we tested to verify whether the eight review steps we were able to identify as
required were performed, noting only two had documentation to indicate the review phase
had been conducted.
Similarly, none of the six samples retained documentation indicating that the customer was
informed of the final determination of their application. Lastly, no documentation was
available for one of six samples, which Special Events and Economic Development staff
explained may be due to the application being processed by the Parks and Recreation
Department and retained within their systems instead.
Event
Fully
Documented
Customer Receipt
Retained
Identified
Review Steps
Review Steps
Documented
Customer
Communications
Annual Beach Party No Yes 4 1 None
Fireworks Fest No No Unable to
Determine
2 None
Glendale Glitters No No Unable to
Determine
2 None
Jonah’s 7th Birthday No No Unable to
Determine
None None
New Year’s Eve Live No No Unable to
Determine
2 None
Taylor Swift Concert
2023
No Yes 4 1 None
EDD leadership is aware of the challenges with leveraging systems for tracking applications
and consistently retaining relevant documents and is reportedly working towards
implementing a new permitting system (Clariti), which is anticipated to resolve many of the
existing challenges.
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Cause
The coordination between EDD staff and departments involved in the review process is
suboptimal, and challenges are exacerbated by a lack of uniform access to a singular
permitting system for all key contributors. This is due to many factors, including:
• The City only has 10 subscriptions to the Jotform platform used to intake the special events
application, leading the Special Events team to supplement new application communications
through email. Additionally, EDD staff reported that seven current subscription holders are not
contributors to the application review process, such as some administrative assistants and City
emergency management technicians (EMTs). As a result, while the Jotform platform has an
automatic email function to assist with application intake and distribution, EDD is unable to fully
take advantage of it.
• Occasionally, reviewing departments may reject an application, but will not communicate the
reason why and what components are needed to complete the application. In these scenarios,
Special Events team members experience operational disruption because they need to
independently reach out to department reviewers to verify the information to relay to the
customer.
• The City uses the SmartGov system for liquor license permitting. When the liquor licensing
department finishes their review of an application, it issues the permit within the SmartGov
system, without informing or alerting anyone else involved the application review process.
• Some departments request that submitted applications be provided 30 days before the event,
while other request for a 60-day advanced receipt of the submitted application. These
preferences introduce complexities for the review that require additional manual work to track.
• Customers may sometimes submit their application or supplemental document late. In pursuit of
customer service, the City would often work around time window restrictions to help the customer
to be able to host their event. This furthers the complexity for managing, monitoring, and
developing a systemic and standardized review process.
Effect
The lack of standard operating procedures for reviewing special event applications can have
a number of negative effects on the City and its customers. The urgency-based, ad-hoc
review process and internal coordination challenges can lead to a complex, inconsistent,
and elongated review process, which can result in delays and non-compliance with code
review requirements. This can erode trust and relationships with special event organizers,
limiting opportunities for continued economic development and growth.
Additionally, customers may be unable to host their events to their liking, or at all, if essential
information is not provided in a timely manner. This can result in lost revenue and
opportunities for the City and local businesses. Altogether, the City may face heightened
barriers for business and an increased risk of non-compliance as well, particularly when in a
rush to complete application reviews. Non-compliance can result in penalties, fines, and
other consequences that can negatively impact the city’s reputation and event opportunities
in the long term.
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Recommendation
The City should continue work to implement Clariti as its permitting system for intaking
special event applications, reviews, and approvals. As the system goes live, EDD leadership
should ensure that key contributors in the application review process have adequate access
to it. Evaluating boundaries and access parameters to find a balance between access to
information and adequate controls is essential to avoid excessive authorization (e.g., view-
only access vs. permissions to edit). Customer access should also be considered to help
streamline communications.
It can be beneficial for EDD to introduce a fee schedule that incentivizes event organizers to
complete their applications early. A fee schedule that increases application costs as the
event application is submitted closer to the start of the event can influence customers to be
more consistently timely with their application and supplemental document submissions and
provide an additional source of resources that can support long-term special events
processing success.
MANAGEMENT RESPONSE
Management Agreement Division leadership concurs with the recommendation.
Owner Special Events Administrator
Target Completion Date TBD - Dependent upon Clariti implementation schedule
Action Plan
The Special Event Division team will work with the city’s Clariti Implementation
Team to develop and eventually deploy the ability to process and review all
special event applications through the same platform that is used by all
review/inspection departments. Division will also evaluate an incentive for an
early submissions model as part of the overall fee review.
8. Finding The City’s definition for special events is broad and focused on events
held on city-owned property. This can lead to excess work and
elongated processing timelines for small-scale community events, such
as local shop tabling, tree lots, and pumpkin patches; and less
comprehensive reviews for private events.
Recommendations A. The City should continue its efforts to update the municipal code to
ensure event hosts properly permit their events regardless of
location, and also differentiate small community events from special
events to expedite their review and approval.
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B. The City should revise policies, procedures, and application forms
for separate event categories in alignment with the updated
municipal code.
Criteria
Cities should define organized events effectively to ensure that they are well-managed,
processed effectively, minimize community disruptions, and promote public safety. The City
should have guidelines that clearly define events as special events based on event size,
purpose, and complexity and impose review requirements for events in proportion to these
factors. It should also ensure all events are properly and comprehensively reviewed, with all
event aspects that require permits, having permits.
Peer Analysis
All peer locations approached application reviews with efficiency and event scale in mind:
• The Town of Gilbert processes event applications holistically. Applications have a monthly
submission deadline, and all submitted applications are assessed at a monthly special events
approval meeting to determine which departments should be involved.
• The City of Anaheim streamlined the review for carnivals/circuses, Christmas tree lots, pumpkin
patches, and fireworks stands by separating them from other events and creating a supplemental
form with a straightforward checklist of application submission items.
• The City of Santa Monica classifies events for local shops and vendors that involve setting up a
table in a public space as a “brand activation” event. This allows them to offer a shortened review
process and turnaround timeline because these events tend to be relatively small and simple,
with minimal public space accommodation necessary.
• The City of Pasadena does not classify its events but defines an event as a gathering that is open
to the public, has advertisements, and invites attendees. All events undergo review. However, the
review process is tailored to each application based on event size, allowing the city to expedite its
review of smaller events such as seasonal lots.
Condition
Currently, the City intakes event applications through the use of its SEMA. All event
organizers interested in hosting an event are asked to submit a SEMA and varying degrees
of additional materials for review. Submitted applications undergo the review process
chronologically, being passed onto relevant departments for review as deemed necessary.
Under current practices, all events are assessed similarly to determine the appropriate
review pathway, regardless of how standard or simple they may be. Additionally, City staff
are cognizant of their lack of authority over events held on private property, which are
technically exempt from the application process according to the current municipal code.
However, in practice, events held on private property may also trigger permit requirements
to protect public safety. As part of our work, we reviewed a list of all special events held
within the City during the 2023 calendar year. Among the 220 special events held, we
identified events that appear to be smaller in scale and may warrant a separate, simpler and
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shorter review process—notably, birthday parties, tree lots, vendors for Valentines gifts, and
a wedding.
EDD employees reported that work on revamping the definition of a special event has
initiated. This work started with ensuring the review team collectively understood the
definitions set up by the Glendale municipal code and is planned to continue through
adjustments to key definitions and terms.
Cause
The City defines events as gatherings in public spaces and public facilities in Section 29.2-1
of its municipal code. The code states that an event is either a large special event or a
special event. It describes a special event to be a preplanned gathering that will impact
natural public activity, safety measures, or traffic and designates a special event as large
when it is expected to draw more than 500 attendees. Because of this, the City essentially
only requires events on properties and facilities maintained or controlled by the City to be
reviewed. Additionally, all public property events regardless of size or complexity undergo a
singular special events review process.
Effect
Defining all events as either a special event or a large special event leads to elongated
review times, process bottlenecking, and sustained high workloads for special events
staff. Smaller events such as local vendor tables and cyclical events, such as tree or
pumpkin lots, can be encumbered by the lengthy special events review process. Confusion
caused by process inconsistencies (see also Event Review Process Inconsistencies) can
compound and lead to excess review work for low-risk events. Customers and vendors
interested in hosting these types of events may feel intimidated by the requirements and
process. Overall, this environment can lead to less efficient use of City staff time and
resources. It also prevents the City from using a risk-based approach to administering
special events, as both small and large-scale events are reviewed to the same degree.
The City’s definition of special events as those in public spaces and facilities is constricting
and allows for applicants familiar with the City municipal code to argue against having to
complete the SEMA and event application process for events hosted on private property.
This means the City is vulnerable to heightened public safety risks, particularly if private
property events feature elements that require permits. For example, because events on
private property are not required by municipal code to undergo the application process, it is
possible a large stage or tent that requires a building and safety permit is used by the
general public without proper City permitting and vetting. While the City would be able to
require permitting for the stage, it could potentially not be aware of its presence.
Recommendation
The City should continue its efforts to update the municipal code to comprehensively govern
all events occurring within city boundaries, and to differentiate low-risk, smaller events from
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other special event types to allow the City to streamline processing, review, and issuance for
relatively easy and quick events. Revised definitions and policies should be carried through
to policy documentation and clearly define timelines for regular and smaller events. To
facilitate this transition to separate regular and smaller event categories, the City could
develop different applications for each type of event. Different applications may be
particularly beneficial for cyclical events (such as Christmas tree lots and pumpkin patches)
and small-scale events (such as local vendors and individual-centric celebrations).
As the City deliberates a strategic differentiation of event types, it should consider the
following elements:
• Clarity: The definition of each event category should be clear and easy to understand, to ensure
that event organizers, application reviewers, and other stakeholders know what is required for
them.
• Scope: The definition of special events should be broad enough to encompass a wide range of
events, but specific enough to ensure that events that fall within the category are large and
complex enough to warrant a heightened degree of administration and that events that pose a
risk to public safety or violate any laws or regulations are not permitted.
• Criteria: The definition of special events should include specific thresholds and criteria for
determining whether an event qualifies as a special event, such as the number of attendees, the
duration of the event, the location, or any specified combination of permits required.
• Process: Each event type should ideally have an associated process for submittal, review, and
obtaining permits and approvals. Clear parameters will help event organizers understand the key
information related to their event.
Overall, defining special events effectively is essential for using a balanced, risk-based
approach to review applications while adequately preserving public safety and minimizing
disruptions to the community.
MANAGEMENT RESPONSE
Management
Agreement Division leadership agrees with this recommendation.
Owner Special Events Administrator/Deputy Director of Economic Development
Target Completion
Date September 30, 2025
Action Plan
Division leadership will continue to meet with the internal working group
comprised of all departments that review special event applications to revise
policy and ordinance language (a first draft of edits to the existing ordinance have
already been drafted).
Once a final draft of proposed language is agreed upon by the internal working
group and the attorney’s office, the draft will be presented to city leadership.
A final draft of the proposed ordinance change will be presented to City Council
for formal adoption.
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Internal administrative policies will be put into operation as approved by city
leadership.
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APPENDIX A: SPECIAL EVENTS PROCESSING PEER CITY BENCHMARKING MATRIX – JULY 2024
The City engaged Moss Adams to conduct a performance audit of its EDD with specific focus on resource utilization, special events, and contract management processes. As part of this work, we reached out to eight peer
cities to learn about how they process special event applications and were able to meet with four localities: Gilbert, AZ; Anaheim, CA; Pasadena, CA; and Santa Monica, CA. Our discussions focused on each municipality’s
definition of special events, application review processes and timelines, and application tracking and monitoring practices and systems. The following table provides an overview of key characteristics of each location, a
summary of lessons learned, and best practices.
TOWN/CITY SPECIAL EVENT DEFINITION CUSTOMER SERVICE POINTS SPECIAL EVENTS TEAM STAFFING SYSTEM(S) USED REVIEW PROCESS PROCESS TIMELINES
Gilbert, AZ Any gathering on town property, or
on private property if it requires
town services (police or fire
department), or it exceeds 500
attendees.
Event promoters contact the Recreation Coordinator to
discuss their event and identify required documentation
and permitting steps.
The applicant emails their application to the Recreation
Coordinator for input into the permitting system.
Applicants may be asked to attend pre-event meetings
for large events.
1 Recreation Coordinator Monday.com for
organization, ACTIVEnet
as the permitting system,
Email and Microsoft
Teams for
communication
The Recreation Coordinator is responsible
for monitoring applications from start to
finish.
The Recreation Coordinator and a
representative from each of the reviewing
departments meet on a monthly basis to
discuss applications.
Applications are requested to be
submitted at least 30 days in
advance of the event.
The Town must issue an approval or
denial of the application within 15
days of submittal.
Glendale, AZ Any preplanned gathering that will
impact natural public activity, safety
measures or traffic.
Applicants submit documents through the Jotform
portal.
Applicants communicate via email, phone call, or in
person with Special Events staff to complete their
application.
1 Special Events Administrator,
1 Development Services
Representative
1 Special Events Program Manager
Jotform for receiving
applications, Hansen for
permitting, Cerberus for
recordkeeping, and
Email
The special events team receives notice of
an application submission and routes it to the
various departments for review through the
Hansen system and via email.
Applications must be reviewed within
10 days of receipt, or 15 days with
an extension.
Applicants may be asked to submit
applications earlier depending on the
event.
Anaheim, CA Any gathering that will use public
spaces or spaces available to the
public in the Anaheim Convention
Center.
Carnivals and circuses are a
separate category.
Applicants submit documents through the electronic
plan review system GoPost.
Applicants work with the assigned Planner to complete
their application.
In-person appointments can be requested for further
assistance.
1 Principal Planner and Associate
Planners Email, Momentus for
CRM and recordkeeping,
GoPost for accepting
submissions, Accela for
permitting and
documenting permit
approvals, and Email.
The Principal Planner assigns submitted
applications to other department Planners.
Planners are responsible for routing their
application to EDDs and communicating
additional document requests and reviewing
progress or completion to the customer.
Applications must be submitted 14
days prior to the event for review.
Pasadena,
CA
A gathering that is open to the
public and advertises to invite
attendees.
Private events are managed by
Parks and Recreation, and large-
scale events are handled by the
City Manager’s Office.
Customers upload documents to their OneDrive folder,
or email documents to Events Program Coordinators
who upload the documents to OneDrive.
Customers work with one of the two Events Program
Coordinators to complete their application. In-person
support is also available upon request.
2 Full-time Events Program
Coordinators
1 Part-time Office Assistant
OneDrive and Email Part-time Office Assistant reviews
outstanding applications monthly and
communicates pending documentation to the
Events Program Coordinators.
Special Events Office staff serves as a
liaison for the customer and internal
departments that need to review
applications.
All applications must be submitted at
least 4 months prior to the event
start date (6 months for large special
events).
Santa Monica,
CA
Events are categorized as a
complex event, community event,
or a demonstration.
They can be hosted in public, at the
Santa Monica Pier or the Santa
Monica Promenade.
Customers answer a scoping questionnaire and receive
a list of required documentation for their event.
They work with one of the two Community Recreation
Administrators to complete their application, which they
submit online.
2 Community Recreation
Administrators OpenCounter for
recordkeeping and
permitting, Excel
spreadsheet as an event
log, and Email for
communications
A Community Recreation Administrator
ushers their assigned application through the
appropriate reviewers and serves as a
liaison for the customer and internal
departments.
With the exception of some
community events1, all applications
are required to be submitted 30 days
prior to the event start date.
1. The City classifies small community events hosted for the purpose of promoting brand awareness and marketing as “brand activations” and only requires 10-day advanced submission with one of the two hosting locations (the Pier and the Promenade).
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Application Clarity and Applicant Understanding
• A simple user interface can ensure that customers understand what is expected of them.
Employing a single point of contact for customers tends to be a low-barrier way to achieve this.
• It can be helpful to onboard new event hosts to provide them with an overview of the process and
highlight key phases or steps where applications tend to get stuck, such as commonly missed
documentation.
• Clear and direct communication with the customer to inform them of deadlines (e.g., if a
supplemental application is not provided by a certain time, they will not be able to include a
specified activity within their event) can be helpful to set expectations.
• Most cities work to identify supplemental documentation early on for applicants, typically through
a questionnaire or additional instructions on their special events application. This can emphasize
the need for additional documents to the applicant early.
• In-person accommodation is an important option for customers that may not be able to apply
electronically.
• Using a checklist for each kind of event category can further clarify customer documentation
requirements.
• Shorter applications that balance informing customers (e.g., tents that exceed 400 ft. must be
reviewed by the fire department) with instructing them (e.g., if 400 ft+, apply for fire permit) can be
easier to digest for customers.
• Including deadlines within customer communications as applicable can be helpful to keep
customers on track in submitting their outstanding documents.
• Communication with customers can also include positive messaging and express appreciation for
the customer’s timely submissions and responsiveness and engagement throughout the
application process.
• Educating council members about the special event permitting process and review lead-times can
help temper expectations.
Application Monitoring and Prioritization
• It can be helpful to separate event applications from regular hosts (e.g., recurring vendors), hosts
for large special events (e.g., the Superbowl), and smaller and first-time hosts.
• Application reviews for smaller ventures could potentially be simplified. Small, local vendors that
want to host a marketing-type event may not necessarily need to undergo a special events
process.
• It is important to recognize that first-time customers may also require additional support
throughout the application process.
• Having dedicated administrative staff to monitor outstanding applications can be an effective way
to track application progress and ensure completeness of application review.
• To circumvent challenges in digital processes, staff can have customers provide their documents
directly and transfer them to the permitting system.
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Streamlining and Simplifying Processes
• It can be helpful to partner with venues and leverage their support to review applications. This
could be beneficial if many similar events are regularly being applied for in a concentrated area.
• A list of pre-approved food truck vendors can help less experienced event hosts by allowing them
to avoid the cumbersome process for permitting food concessions.
• Identifying one point of contact in each department involved in reviewing can further streamline
the review process and simplify the tracking of application progress.