“it's seeing an increase in their filings in pursuit of incentive programs, and they are often "procedurally or substantively deficient,"
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“The firms need to file properly and avoid programs that could incentivize bad behavior
“procedurally or substantively deficient
“has provided adequate notice of the terms of the program and sufficiently evaluated the program’s compliance.
“"So that's why we want to focus the administration's attention on this problem that could undo all of the good work that they're doing to speed up permitting,"
“the agency could impose constraints, including requiring officials to consider costs imposed on permit holders and their reliance on previously issued permits
“city officials should have conducted an ‘individualized statutorily-required initial determination’ before issuing the notices to homeowners, so as to not place the burden on the property owners.