[Audit Report on Building Permit Fees, Department of Planning and Natural Resources, Government of the Virgin Islands]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 98-I-191

Title: Audit Report on Building Permit Fees, Department of Planning
       and Natural Resources, Government of the Virgin Islands

Date: December 30, 1997

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V-IN-VIS-002-96

United States Department of the Interior

OFFICE OF INSPECTOR GENERAL
    Washington, D.C. 20240

Honorable Roy L. Schneider
Governor of the Virgin Islands
No. 21 Kongens Gade
Charlotte Amalie, Virgin Islands 00802

Subject:  Audit Report on Building Permit Fees, Department of Planning and Natural
Resources, Government of the Virgin Islands (No. 98-I-191)

Dear Governor Schneider:

This report presents the results of our review of the building permit function of the Virgin
Islands Department of Planning and Natural Resources. The objective of the audit was to
determine whether the Department's Division of Permits had policies and procedures in place
to: (1) review and approve building and other related permit applications in an equitable and
timely manner; (2) inspect and effectively enforce standards for construction projects; and
(3) adequately control permit fee collections. The scope of the audit included a review of the

Division's operations that occurred during fiscal years 1995 and 1996.

We found that, although the Department had reviewed and approved over 6,000 building and
other related permits during fiscal years 1995 and 1996, improvements were needed in the
areas of permit approval procedures and enforcement activities. Specifically, we found that
the Division of Permits:

      -  Allowed developers to construct buildings without required permits and did not
ensure that: (1) architectural plans were always reviewed; (2) the correct permit fees were
assessed and collected; (3) and permit files were properly maintained. As a result of these
conditions, the Division was not always aware of structures that were under construction and
lost at least $155,069 in permit fees.

      -  Did not adequately enforce building code requirements and document actions
taken with regard to building deficiencies. As a result, building deficiencies were not
corrected, violators were not penalized for building code violations, and the public was
potentially at risk because of construction that was not in compliance with building codes.

On October 3, 1997, we transmitted a draft of this report to you requesting your comments
by November 2 1,1997. At the request of the Department of Planning and Natural Resources,
we granted an extension until December 5, 1997. However, a response to the draft report
has not been provided. Therefore, since this final report is being issued without the benefit
of your response, all of the recommendations are considered to be unresolved (see
Appendix 2).

 
The Inspector General Act, Public Law 95-452, Section 5(a)(3), as amended, requires
semiannual reporting to the U.S. Congress on all audit reports issued, the monetary impact
of audit findings (Appendix l), actions taken to implement audit recommendations, and
identification of each significant recommendation on which corrective action has not been
taken.

In view of the above, please provide a response, as required by Public Law 97-357, to this
report by January 30, 1998. The response should be addressed to our Caribbean Regional
Office, Federal Building, Room 207, St. Thomas, Virgin Islands 00802. The response should
provide the information requested in Appendix 2.

We appreciate the assistance of Department of Planning and Natural Resources personnel in
the conduct of our audit.

Inspector General

cc: Ms. Beulah Dalmida-Smith, Commissioner,
  Virgin Islands Department of Planning and Natural Resources
Mr. Elmo D. Roebuck, Special Assistant to the Governor
  for Policy and Audit Resolution

 
CONTENTS

Page

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  1

BACKGROUND  ................................................  1
OBJECTIVE AND SCOPE  ........................................  1
PRIORAUDITCOVERAGE  ......................................  2

FINDINGS AND RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  3

A. BUILDING PERMIT APPROVALS ..............................  3
B. BUILDING CODE ENFORCEMENT  ............................. 8

APPENDICES

1. CLASSIFICATION OF MONETARY AMOUNTS  .................. 12
2. STATUS OF AUDIT REPORT RECOMMENDATIONS  ............. 13

 
INTRODUCTION

BACKGROUND

The Division of Permits of the Virgin Islands Department of Planning and Natural Resources
was established to administer and enforce the Virgin Islands Building Code and the Zoning
Laws. The Building Code (Title 29, Chapter 5, of the Virgin Islands Code) was developed
to "safeguard life and limb, property, and public welfare, through the establishment of
minimum building requirements for structural strength and stability." After Hurricane Marilyn
caused extensive damage to homes, businesses, and other structures in September 1995, the
Virgin Islands Legislature enacted Act No. 6087, which incorporated (by reference) the 1994
Uniform Building Code and the 1995 Council of American Building Officials One and Two
Family Dwelling Code into the Virgin Islands Building Code. The Zoning Laws (Title 29,
Chapter 3, of the Virgin Islands Code) were developed to promote "the health, safety, morals
and general welfare of the community by establishing regulations and conditions governing
the erection and use of buildings and other structures and the use of land and water for trade,
industry, residence and other specified purposes."

The Division of Permits has offices on both St. Thomas and St. Croix and, as of June 1996,
had 38 employees. The Division had budgets of $1.4 million and $1.35 million for fiscal years
1995 and 1996, respectively. During fiscal years 1995 and 1996 (through August 1996), the
Division issued 2,050 building, 1,798 electrical, 1,025 plumbing, and 1,342 earth change
permits. Permit fee collections totaled $309,000 during fiscal year 1995 and $300,000 during
fiscal year 1996 (through June 1996).

OBJECTIVE AND SCOPE

The objective of the audit was to determine whether the Division of Permits had policies and
procedures in place to: (1) review and approve building and other related permit applications
in an equitable and timely manner; (2) inspect and effectively enforce standards for
construction projects; and (3) adequately control permit fee collections. The scope of the
audit included a review of the Division's operations that occurred during fiscal years 1995 and
1996. The audit was performed at the offices of the Division of Permits and other units of
the Department of Planning and Natural Resources on St. Thomas and St. Croix. In addition,
we visited a total of 14 building sites on both islands to determine whether building permits
had been issued for the construction work at those locations.

Our review was made, as applicable, in accordance with the "Government Auditing
Standards," issued by the Comptroller General of the United States. Accordingly, we
included such tests of records and other auditing procedures that were considered necessary
under the circumstances.

As part of our review, we evaluated the Division's internal controls related to the approval
and issuance of building and other related permits, the collection of permit fees, the inspection
of structures, and the enforcement of construction standards to the extent that we considered

1

 
necessary to accomplish the audit objective. The internal control weaknesses noted in these
areas are addressed in the Findings and Recommendations section of this report. Our
recommendations, if implemented, should improve the internal controls in these areas.

PRIOR AUDIT COVERAGE

The Office of Inspector General has not issued any prior audit reports on the Division of
Permits of the Department of Planning and Natural Resources.

 
FINDINGS AND RECOMMENDATIONS

A. BUILDING PERMIT APPROVALS

The Division of Permits did not conduct its permit approval operations in an efficient and
effective manner. Specifically, we found that: (1) developers constructed structures without
required permits and without architectural plans being reviewed and approved; (2) permit fees
were not always correctly assessed or collected; and (3) files were not always maintained
properly. Title 29, Chapter 5, of the Virgin Islands Code and the 1994 Uniform Building
Code contain requirements for the issuance of building permits and the guidelines for record
maintenance. However, the deficiencies occurred because the Division did not: (1) establish
standardized procedures for its review and approval functions; (2) effectively communicate
to developers its processing requirements and the status of applications for permits;
(3) charge the established fees; (4) have a sufficient number of plan reviewers in the St. Croix
office; and (5) have adequate file management procedures and file storage space. As a result,
the Division lost at least $155,069 in permit fees (about one-half of an average year's
collections) and was not always aware of structures that were constructed by developers
without the required permit approvals.

Required Permits

Section 106.1 of the 1994 Uniform Building Code requires that the "building" official issue
a separate permit for each structure being erected, constructed, enlarged, altered, repaired,
moved, converted, or demolished. In addition, Title 29, Chapter 5, of the Virgin Islands Code
requires that developers, before beginning construction, request a building permit by
submitting to the Division of Permits a completed application, architectural plans for the
structure, and a $2 application fee. The Division reviews the application to determine
whether the developer is required to pay an earth change permit fee of $50 for land clearing
and testing of soil or a Coastal Zone Management permit fee, which can range from $50 to
$1,000, for developing along the coastline. The Division then reviews and approves or
disapproves the architectural plans. If the application and the plans are approved, the

Division then issues the building permit, charging the applicable permit fee. The Virgin

Islands Code also requires the contractor to apply for plumbing and electrical permits if this
type of work is going to be performed within the structure. The Division determines the
amount of fees for building, plumbing, and electrical permits based on the Division's estimate
of the cost of construction, as discussed in the section of this report on "Permit Fee
Collections." The Division's policy, as stated in a February 1995 letter to an electrician, is
that permits are not valid or effective until the applicants pick up the permits and pay the
applicable fees.

Our review showed that, despite these requirements, developers performed construction,
repair, and renovation work on structures without having valid building and other applicable
permits. For example, we reviewed a random sample of 352 building permit files (229 on
St. Thomas and 123 on St. Croix) and found that 171 files (105 on St. Thomas and 66 on
St. Croix) were missing at least one required permit (electrical, plumbing, or occupancy). We

3

 
also visited a total of 14 construction sites on St. Thomas and St. Croix and found that, in IO
instances, structures had been constructed or repaired without approved building permits.

Further, the Division had, in its possession, 517 approved architectural plans, 484 plumbing
permits, and 767 electrical permits that had not been picked up and paid for by the applicants.
Therefore, according to Division policy, these permits were not valid, and any construction,
plumbing, or electrical work performed by the applicants was done without the required
permits being in effect. Additionally, the Division had not been paid a total of $143,446 in
fees related to these permits. These conditions existed because the Division did not:
(1) effectively publicize the policy that permits are not valid until they are picked up and paid
for; (2) inform applicants when their permits had been approved and were ready for pick up;
and (3) aggressively enforce the established permit requirements.

When a building permit is issued for new construction, the developer is entitled to obtain
temporary electrical power through an electrical meter (commonly referred to as a
"construction meter") from the Virgin Islands Water and Power Authority. After a final
inspection of the constructed facility, the Division issues an occupancy permit, approving the
structure for occupancy. At that time, the developer can apply to the Water and Power
Authority for permanent electrical service. However, we found that developers were
occupying structures that had not been completed or, for other reasons, had not been issued
occupancy permits.  In such cases, the occupants continued to use the temporary
"construction meters," as long as 20 years in one case, that were meant to provide electrical
service only during the construction phase. Our review of the Division's files disclosed 33
instances in which required occupancy permits had not been obtained by the developers.

The Division's Acting Director on St. Thomas told us that, in his opinion, the Division and
the Water and Power Authority needed to better coordinate their activities so that the
Authority could inform the Division of instances in which structures that had not been
approved for occupancy were being occupied with continuing use of temporary "construction
meters."

Building Plans

Although Section 106.4 of the 1994 Uniform Building Code requires that architectural plans
be reviewed and approved before a building permit is issued, the review of the plans was not
always documented by the Division. We found 32 instances, out of the 352 building permit
files reviewed, in which the checklist designed for use during the review of plans was not filed
with the approved plans. Plan reviewers are responsible for ensuring that building plans meet
zoning, structural, plumbing, electrical, cistern capacity, and septic capacity requirements.
The chief building inspector is responsible for providing final approval of the reviewed plans.
However, we found six instances in which the same building official reviewed and approved
plans. These deficiencies occurred because the Division did not have formal policies and
procedures regarding the plan review process.

The Division's St. Croix office had a backlog of 83 plans awaiting review and approval
because it took as long as 2 months to review the plans. For example, a set of plans was

 
submitted to the Division on July 1, 1996, but it was not reviewed until September 3, 1996.
This situation occurred, in part, because the St. Croix o&e had only one plan reviewer, and
when this employee was absent, a backlog occurred. We also found that, as of October 22,
1996, 217 sets of plans at the Division (some since 1991) needed to be corrected by
draftsmen. An official of the Division told us that the large number of corrections was
attributable to the lack of technical experience on the part of some draftsmen and their
unfamiliarity with the new building code. (The issue of the testing of applicants for business
licenses as draftsmen, architects, and building contractors will be discussed in a separate audit
report on the Division of Licensing, Department of Licensing and Consumer Affairs.)
Division personnel also stated that the structures for which the pending building plans had

been prepared may already have been constructed.

The Division also issued building permits based on "as built" plans and plans with
"conditions. " " As built" plans are those that are submitted for review after construction has
been started or, in some cases, completed. Since those structures were not inspected, there
was little assurance that they were constructed in accordance with the building code
requirements. Our review of 352 building permit files disclosed 4 instances in which building
permits were issued on the basis of "as built" plans. Additionally, the Division's Permits
Manager on St. Thomas told us that "most" of the 67 building permits issued to Government
of the Virgin Islands agencies for reconstruction and repair work after Hurricane Marilyn
were based on "as built" plans, meaning that the architectural plans were prepared and
approved after-the-fact. In one instance that was widely reported in the local news media,
the roof of a public school that was rebuilt after Hurricane Marilyn in September 1995 was
blown off of the school by Hurricane Bertha in July 1996, suggesting that the new roof may
not have met the stricter building code requirements implemented after the 1995 hurricane.

Under "structural conditions," plans are approved and building permits are issued, although
either: (1) changes are needed in the plans to provide adequate roof reinforcement, proper
building materials, adequate cistern or drain field capacity or (2) a structural engineer's
approval is needed. Under "nonstructural conditions," plans are approved and building
permits are issued, although certain additional documents, such as driveway access permits,
earth change permits, sewer permits, title deeds, or environmental protection approvals, are
needed. We found that 31 plans at the St. Croix office had been approved with

structural (7) and nonstructural (24) conditions.

Permit Fees

The Division of Permits did not always charge the correct permit fees, which resulted in the
loss of at least $11,623 in fees. The permit fees vary depending on the estimated cost of
construction. For example, the building permit fee for one- and two-family dwellings starts
at $5 for construction costs of up to $1,000 and increases by $2.50 for each additional $1,000
of construction cost. After Hurricane Marilyn, the building permit fee for dwellings that
house three or more families and for commercial structures was increased as part of the
adoption of the 1994 Uniform Building Code. The new fee rates ranged Tom $22 for
construction costs of up to $500 to $4,955 for the first $1 million of construction plus $2.75
for each additional $1,000 of construction costs above that amount. In addition, we found

5

 
that the Division charged twice the normal fee rate for "as built" permits. However, the
Division's St. Croix office did not apply the 1994 Uniform Building Code fee structure for
dwellings that housed three or more families and for commercial structures because,
according to Division officials, that office had not been informed of the change afier
Hurricane Marilyn. For example, we found that commercial developers were charged $305
instead of $3,397.35 (including a plan review fee) for construction costs of $332,800; $505
instead of $5,412 (including a plan review fee) for construction costs of $600,000; and $320
instead of $3,943.50 (including a double fee for an "as built" permit) for construction costs
of $160,000. As a result, fee revenues of $11,623 were lost in these three instances. We also
found that the Division was still charging a $2 application fee to have building plans reviewed
instead of charging a plan review fee of 65 percent of the applicable building permit fee as
required by the 1994 Uniform Building Code.

Although the various fees were paid to the responsible collectors at the Department of
Planning and Natural Resources, the collectors did not record payment information on the
Department's copies of the issued permits. Therefore, we were generally unable to trace the
collections to the respective permits. After we brought this matter to the attention of the
Department's collections supervisors, they informally directed the collectors to record
payment information on the permits. We also found that although collections were deposited
daily, supervisors were not reviewing and reconciling the collections and deposits on a daily
basis.

File Management

Title 29, Section 297(j), of the Virgin Islands Code requires that accurate records be
maintained "of [building] inspections made, of notices issued, and of actions taken by builders
and owners pursuant to notices resulting from inspections." However, our review disclosed
that such records were not centralized or complete. For example, we found that 16 building
permit files (of 352 files reviewed) could not be located at the Division, and we noted that
documents such as permit applications, earth change and/or coastal zone permits, plumbing
and electrical permits, occupancy permits, inspection reports, incident reports, and notices of
violations were not maintained in a single file for each case. This made it difficult for Division
personnel to know the status of each construction project from beginning until final inspection
and approval. Additionally, employees maintained their own personal files. Further, the
Division had its copies of approved building plans located in several offices, which made it
difficult to locate approved plans. An official told us that the Division did not have adequate
storage space to secure these records. We also noted that the Division did not have formal
file management procedures to ensure that all pertinent documents were maintained in
consolidated permit files and that employees signed out for files that they removed from the
main storage areas.

Recommendations

We recommend that the Governor of the Virgin Islands direct the Commissioner of Planning
and Natural Resources to:

 
    1. Develop and implement formal written procedures for the permit application,
processing, and approval functions. The formal written procedures should address the types
of permits required and the applicable fee schedules, the use of a checklist during the review
of architectural plans, the situations in which "conditional" permits may be issued, the
followup actions to be taken if property owners and/or building contractors do not pick up
and pay for approved permits or if permits are disapproved because of some defect in the
architectural plans, and the types of documents that should be maintained in permit case files.

    2. Develop and distribute to the public detailed information on the building permit
requirements to inform property owners and building contractors about the types of permits
required in different situations, the appropriate application procedures, the related permit fee
schedules, and the Department's policy that approved permits do not become valid until they
have been picked up and paid for.

    3. Develop a system to inform applicants when approved plans and permits are ready
to be picked up.                                                            9

  4. Request that the Virgin Islands Water and Power Authority inform the
Department of Planning and Natural Resources of property owners who continue to use
temporary electrical service ("construction meters") after occupying the property so that the
Department can follow up to determine whether those property owners have been issued
occupancy permits.

    5. Provide the St. Croix office with a sufficient number of plan reviewers to ensure
that architectural plans are reviewed within a reasonable time frame.

    6. Consider replacing the current $2 application fee with the plan review fee that is
provided for in the 1994 Uniform Building Code. The plan review fee should be paid by
developers when they submit architectural plans for review.

    7. Develop and implement formal file management procedures to ensure that permit
files contain all documents showing the review, approval, and inspection history of each case,
including evidence of followup actions taken to correct deficiencies identified by the
Department's inspectors and enforcement offkers. The procedures should also include a
system for maintaining control of files removed from designated storage areas.

Governor of the Virgin Islands Response and Office of Inspector General
Reply

The Governor of the Virgin Islands did not provide a response to the draft report. Therefore,
all of the recommendations are considered unresolved (see Appendix 2).

 
B. BUILDING CODE ENFORCEMENT

The Division of Permits did not aggressively enforce building code requirements and
document actions taken with regard to building deficiencies identified during on-site
inspections. The basic requirements for building code inspections are contained in the 1994
Uniform Building Code and in Title 29, Section 312, of the Virgin Islands Code, which
provide guidelines for the enforcement of building code violations. The enforcement
weaknesses occurred because the Division did not have formal policies and procedures in
place for its enforcement efforts, and supervisors did not provide adequate oversight of the
inspectors' work efforts. As a result, building discrepancies were unresolved, developers
were not penalized for building code violations, and the potential existed for the public to be
at a safety risk because of buildings that were not constructed in accordance with the building
codes.

Inspection Practices

Section 108 of the 1994 Uniform Building Code requires that periodic inspections be
performed of structural, plumbing, and electrical work performed. These technical
inspections are the responsibility of the Division's inspections unit. The Code requires
inspections to be performed at certain stages in the construction process. However, periodic
and final inspections were not always performed or adequately documented because of a lack
of written procedures and inadequate supervision of inspectors.

Each inspector is assigned to a particular area of the island and is required to submit a weekly
report of sites inspected and prepare a report of building deficiencies found. However,
supervisors did not always maintain records of construction sites visited by the inspectors, and
the inspectors did not always perform assigned inspections; properly record and report the
deficiencies found; and document actions taken to resolve such problems. Our review of 352
permit files disclosed that 90 files did not have information on whether periodic inspections
had been performed and that 33 files did not contain final inspection reports or approved
occupancy permits. These conditions occurred because the Division did not have formal
supervisory followup procedures. Specific examples of the deficiencies in the inspection
process included the following:

  -  On June 18, 1996, one of the Division's inspectors issued a stop work order for
a structure that was being built without the necessary building permit. However, the
developer continued construction, and on September 24, 1996, the developer submitted the
"as built" architectural plans for the structure. There was no documentation in the Division's
files to indicate whether any attempt had been made to enforce the June 1996 stop work
order.

  -  On July 25, 1996, one of the Division's inspectors wrote to the Department of
Health concerning unsanitary and potentially unsafe conditions caused by a defective septic
system at a local restaurant. However, there was no documentation in the Division's files to
indicate whether: (1) the property owner had submitted plans for the septic system for review

8

 
and approval; (2) a building permit had been issued; or (3) the conditions indicated in the July
1996 letter had been corrected.

  -  On October 22, 1996, one of the Division's inspectors reported that hazardous
conditions existed with regard to the septic system at a building that housed a preschool
facility. However, there was no documentation in the Division's files to indicate whether:
(1) the property owner had submitted plans for the septic system for review and approval;
(2) a building permit had been issued; or (3) the conditions indicated in the October 1996
report had been corrected.

  -  Documentation in the Division's files showed that, as of September 1996, a
hazardous situation existed with the plumbing and electrical systems at a residential complex
on St. Thomas that provides housing for up to 100 persons. For example, raw sewage was
running onto the property and a nearby horse race track. Officials of the Departments of
Health, Licensing and Consumer Affairs, Fire, and Planning and Natural Resources met on
September 27, 1996, to discuss the problem, and the property owner was given 1 week to
have the facility vacated and to begin repairs to the plumbing and electrical systems.
However, there was no documentation in the Division's files to indicate whether a followup
inspection was performed to verify that the property owner subsequently corrected the
problems.

Enforcement Activities

The Division's enforcement officers monitor construction sites to ensure that the necessary
building and other permits have been obtained and are posted. In addition, the officers are
deputized to issue citations or oral stop work orders if the owners are in violation of the
permit requirements. In accordance with Title 29, Section 312, of the Virgin Islands Code,
the Commissioner of Planning and Natural Resources may issue written orders requiring
compliance with the building code, and if compliance is not achieved within 45 days, the case
may be referred to the Virgin Islands Attorney General for legal action. Upon conviction, the
violator may be fined up to $50 for each day that the violation continues.

An official of the Department of Planning and Natural Resources told us that developers
frequently did not comply with the building permit requirements before they began
construction and that, in many such instances, the violation was resolved simply by issuing
the necessary permits "after-the-fact" rather than by fining the violators. We found factors
that contributed to the ineffectiveness of the Division's enforcement activities as follows:
(1) a system was not in place to inform the enforcement officers when permits were approved
and developers were authorized to begin construction; (2) a system was not developed to
handle the administrative procedures necessary to issue the written orders and to take the
legal action specified in the Virgin Islands Code; and (3) a followup system was not
established to document when and how violations were resolved. The following examples
illustrate the types of problems we noted with the enforcement process:

  - In 1992, a homeowner was issued a violation notice because he began
construction without building and earth change permits. A compliance order was issued by

 
the former Commissioner ordering that the offending structure be demolished within 45 days
and stating that failure to comply would result in further legal proceedings. The structure had
not been demolished when we made a site visit on November 14, 1996, and there was no
documentation in the Division's files to indicate whether any actions had been taken to
resolve the violation.

      -  In October 1996, an incident report was filed by an enforcement officer concerning
a homeowner who constructed an addition to his home without a building permit. However,
there was no documentation in the Division's files to indicate whether any actions had been
taken to resolve the violation.

In May 1996, the Commissioner issued two written orders to a homeowner

regarding obtaining and posting of permits. However, there was no documentation in the
Division's files to indicate whether any actions had been taken to resolve the violations.

      -  In June 1996, the Government's Hurricane Recovery Managers recommended that
a stop work order be issued to a contractor because the work being performed on a public
high school was not in compliance with the 1994 Uniform Building Code. However, the
work continued on the school, although the Hurricane Recovery Managers told the
Department of Education that it risked losing reimbursement from insurance proceeds and
Federal Emergency Management Agency disaster funds if the work were to continue. The
Hurricane Recovery Managers' contract with the Government was subsequently terminated
by mutual agreement, and another architectural/engineering firm was hired as the
Government's construction manager. However, there was nothing in the Division's permit
files to indicate whether the potential building code violations had been addressed.

Recommendations

We recommend that the Governor of the Virgin Islands direct the Commissioner of Planning
and Natural Resources to:

    1. Develop and implement formal written policies and procedures for the inspection
and enforcement functions. The policies and procedures should contain provisions to ensure

that inspectors and enforcement officers are notified of approved building permits, record the
results of their visits to construction sites and any problems noted, and submit such written
reports to their supervisors for any necessary followup action.

    2. Develop and implement formal written policies and procedures for monitoring and
following up on the inspection and enforcement functions. The policies and procedures
should contain provisions to ensure that supervisors regularly monitor the activities of the
inspectors and enforcement officers and that appropriate Departmental officials issue written
notices of violations immediately upon identification of building deficiencies and refer cases
that remain unresolved for more than 45 days to the Attorney General for legal action, in
accordance with the Virgin Islands Code.

10

 
    3. Develop and implement policies and procedures for the administrative office of
the Department of Planning and Natural Resources to require that code violations reported
by the inspectors and enforcement officers are tracked to ensure that they are either
satisfactorily resolved or referred to the Attorney General's office for legal action. The
procedures should provide for the maintenance of a complete record of followup actions
taken in each case.

Governor of the Virgin Islands Response and Office of Inspector General
Reply

The Governor of the Virgin Islands did not provide a response to the draft report. Therefore,
all of the recommendations are considered unresolved (see Appendix 2).

11

 
APPENDIX 1

CLASSIFICATION OF MONETARY AMOUNTS

     Finding

A. Permit Approval Procedures

Unrealized
Revenues*

Permits Required                        $143,446
Permit Fee Collections                        11,623

$155.069

* Amounts represent local fhds.

12

 
APPENDIX 2

STATUS OF AUDIT REPORT RECOMMENDATIONS

Finding/Recommendation
  Reference

status        Action Required

A.l-A.7 and B.l-B.3

Unresolved.

Provide a response to each recommendation
indicating concurrence or nonconcurrence. If
concurrence is indicated, provide an action
plan that identifies the target date and the title
of the official responsible for implementation.
If nonconcurrence is indicated, provide
specific reasons for the nonconcurrence.

13

 
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Office of Inspector General
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